Privacy Policy

Privacy Policy

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Last Updated June 27, 2025

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Introduction

Please read the following Privacy Policy carefully.  This Privacy Policy governs and applies to your use of our Web app and our Services. 

By using our Web app, you acknowledge that you have read and understand all of this Privacy Policy, and you agree to be bound by our Privacy Policy. We are sensitive to the concerns that you have about the use of the Information that you disclose to us via our Web app and use of our Services. Accordingly, this Privacy Policy sets forth our privacy practices and the possible uses of the Information that we gather or you provide us through our Web app and Services.

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Spendly, Inc. (collectively referred to herein as “Spendly”, “Company”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites. This Privacy Policy applies to data collection by Spendly and shall apply to your use of the website, www.Getspendly.com and other Spendly-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level Spendly domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy. Any capitalized words not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use.

The Company reserves the right to change this Privacy Policy at any time. If you do not agree to the amended Privacy Policy, you agree to stop using our Web app. You will be deemed to have accepted the amended Privacy Policy if you continue to use our Web app after such changes have been made showing the “Last Updated” date. Any changes will be effective immediately upon the posting the new date.  If changes are made, we will simply change the date appearing at the top of this page to show when the Privacy Policy was last modified, and you agree it is your responsibility to check back often for updates. Your continued use of our Web app after the effective date of a revised version of this Agreement constitutes your acceptance of our updated Privacy Policy. 

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

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Irrespective of which country or state you live in, you authorize us to transfer, store, and use your information in the United States, and any other country or state where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, you agree not to use the Sites or Services.

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If you have any questions or comments about this Privacy Policy, please submit a request to matthew@getspendly.com.

When this privacy policy applies

Our Privacy Policy applies to all of the Services offered by Spendly and its affiliates, including some Spendly Partners, and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

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Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms of use

By accessing or using the Sites in any manner, you also agree to be bound by Spendly’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the Terms of Use contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information we collect

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” or “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data or Personal Information include but are not limited to: full name, contact information including email address, digital identity, such as a login name or handle, information about your device, and certain metadata, phone number, age, gender, IP (Internet Protocol) address, your User handle or User name, geographic location, geo positional data, Information supplied during the processing of registering with us, data usage trends, data showing the effectiveness of promotional campaigns, browser Information, demographic Information, browsing preferences, browsing data, the type of device being used, Web app usage Information, Information regarding any urls used with our Web app, data regarding use of our Web app, other Information relevant to surveys and/or offers, and any other Information we are legally allowed to collect or is required for us to collect to have appropriate operations on our Web app. Additionally, we will have access to your Information, as well as financial and other Information you input  when using our Web ap and software. This Information will also include any Information or data you enter about other people such as your customers, clients, or any other third parties. We require this Information to provide Users with better service. ​As further stated below in this Privacy Policy, we shall not be liable for, and you agree to indemnify us from all such claims by third parties related to your misuse of such third party Information and you represent and acknowledge that you have the express written consent to use the Information provided by those third parties to facilitate business and transactions with them.  

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.

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When you use our Services, we collect Personal Data in the following ways:

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1. Information You Give to Us

As you evaluate whether Spendly is the right solution for your company, you may choose to provide us with Personal Data about yourself, including your name, company name, phone number, and email address by completing forms on our website, such as when you request to contact or make a savings request. You may also choose to provide us with employment and education information when you apply for a job at Spendly via our Site.

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In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.

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The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other Users.

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2. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

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3. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google and similar partners.

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The technologies we use for this automatic data collection may include:

‍Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

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How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

1. To present, operate or improve the Site and Services, including analysis of Site activity;
2. To inform you about Services and products available from Spendly;
3. To authorize access to our Sites and Services;
4. To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
5. To offer and administer programs;
6. To customize or tailor your experience of the Services;
7. To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
8. To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
9. To improve our Site and Services;
10. To secure our Services, including to authenticate Users;
11. To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
12. To respond to and support Users regarding their use of the Sites and Services;
13. To comply with all applicable legal requirements;
14. To enforce our Terms of Use and other agreements;
15. To perform data analysis and testing;
16. To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
17. To resolve disputes;
18. To otherwise fulfill the purpose for which the information was provided.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

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We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. We may use your Personal Data to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We reserve the right to share your Personal Information in response to duly authorized Information requests of governmental authorities or where required by law. We may also disclose your Information if necessary for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of the Company or the Users or to act under urgent circumstances to protect the safety of the Company, its employees, other Users of our Web app, our service providers, advertisers, or members of the public.

From time to time, personal financial information (including credit card information) may be transmitted to facilitate transactions with us between Users who are purchasing our Services. We will not share such personal financial information with third parties other than those third parties such as banks, processing gateways and merchant processors required to process a User’s purchase, and Users understand that we cannot control how the banks, processing gateways or merchant processors will use such personal financial information. Therefore, Users using our Web app and Services hereby consent to such sharing of personal financial information. Each User agrees to assume the risk and agrees that it is their responsibility to properly handle, secure, not store and destroy such personal financial information as may be necessary to protect it from misuse. You agree that we shall not be liable to Users or any third party for misuse of such Content or personal financial information.

We may disclose Information we collect from Users to an affiliate or other third party in the event of any merger, sale, joint venture, assignment, reorganization, liquidation, transfer or other disposition of all or any portion of our business, assets, or stock.

We may use third-party advertising companies to serve ads when Users visit our Web app. These third-party advertising companies may use advertising technologies such as cookies, web beacons and other similar advertising technologies. These companies may use aggregated Information about your visits to our Web app, third party sites, and use of our Services and in order to provide advertisements and promotions about our Services that we believe Users may find of interest. 

We may also release Users Information when we believe release is appropriate to comply with the law, enforce our policies and Terms of Use, or protect ours or other’s rights, property, or safety. However, non-personally identifiable visitor Information may be provided to other parties for data analysis, improving our Services, marketing, promotional, advertising, or other uses.  

From time to time, your personally identifiable information (“PII”) and business financial Information (“Financial Information”) (including, but not limited to, banking information, credit card information, payment facilitator details, or other financial information) may be transmitted to facilitate transactions between you and us. Unless you authorize us as part of the Services we provide, we will never share such Financial Information with third parties other than those third parties such as payment facilitators, banks, processing gateways, financial intermediaries, and merchant processors required to process and facilitate the sending and receiving of payments, and you understand that we cannot control how these third parties will use such Financial Information to perform their services to facilitate payments. Therefore, you hereby consent to such sharing of Financial Information. You agree to assume the risk and agree that it is your responsibility to properly handle, secure, not store and destroy such Financial Information as may be necessary to protect it from misuse. You hereby consent to such sharing of Financial Information and hold us harmless and indemnify us from any claims, breaches, loss, or damage resulting from the use of those payment facilitators, banks, processing gateways, financial intermediaries, and merchant processors we use. You agree we shall not be liable to you or any third party for misuse of such Financial Information.

Under What Other Circumstances May We release PII?

In addition to sharing Your PII with third parties as described above, we may also release Your PII to other third parties if we believe that such release is necessary (a) to comply with the law (e.g., a legal process or a statutory authorization or requirement) or a court order, (b) in order to apply or enforce the Terms of Use, (c) to protect you, other Users, or us  from fraudulent, abusive, or unlawful use of our Web app, or (d) if we reasonably believe that a danger to any person or property requires the disclosure of such PII or otherwise if we believe such a disclosure is needed to protect our interests (as determined by us in our sole discretion).

Our rights under this Privacy Policy may be automatically assigned by us, in our sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees. Without limitation of the foregoing, we may sell, transfer or otherwise share some or all of our assets, including without limitation your PII, with any company under our common control, joint venture, as well as to a potential acquirer and/or an acquirer (including without limitation in connection with a merger, reorganization, or sale of assets or stock, or in the event of bankruptcy). In each such instance, the PII we have collected from you may be one of the assets transferred in connection with such a transaction.

What We Don’t do with the Information We Gather:​                           We will not disclose, sell, distribute, rent, lease or use any of a User’s data, PII, or Financial Information, or the data, PII, or Financial Information of the User’s customers, clients, leasees, payees, mortgagors, or other third parties, or pass on any such data, PII, or Financial Information to third parties, which are not our officers, directors, members, managing members, employees, business partners, affiliates, strategic partners, licensors, licensees, independent contractors, third party service providers, agents or representatives, unless we have your permission or are required by law to do so.  

We do not store your credit card information. The credit card information and actual processing does not take place on and is not stored on our servers. The transaction is processed on the servers of the particular credit card processor we use process the transaction.   

Notice for Residents of Certain Other States

The Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (CPA), and Connecticut Data Privacy Act (CTDPA), and Utah Consumer Privacy Act (UCPA), (“Applicable State Law”) provide residents of those states with certain rights, including the following:

Your Right to Confirm and Access: You have the right to confirm whether we are processing PII about you and access the PII we process about you.

Your Right to Portability: You have to right to obtain a copy of the PII we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format.

Your Right to Delete: You have the right to request that we delete the PII we maintain or process about you.

Your Right to Correct: You have the right to request that we correct inaccuracies in the PII we maintain or process about you, taking into consideration the nature and purpose of such processing.

Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of PII, including:

• Opt-Out of the “sale” of PII as defined by Applicable State Law;

• Opt-Out of targeted advertising by us;

• Opt-Out of automated profiling for the purposes of making decisions that produce legal or similarly significant effects.

If the laws of your state or country of residence differ from what is stated above, please contact Us.

Please note, as explained above, We do not “sell” PII as that word is traditionally defined. 

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Our Legal Basis for Collecting Personal Data

1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:

• Intra-organization transfers for administrative purposes;
• Product development and enhancement, where the processing enables Spendly to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
• Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
• Fraud detection and prevention;
• Enhancement of our cybersecurity, including improving the security of our network and information systems; and
• General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share personal data with companies, organizations and individuals outside of Spendly unless one of the following circumstances applies:

• With your consent. We will share Personal Data with companies, organizations or individuals outside of Spendly when we have your consent to do so.
• Enterprise Accounts. Your employer or your organization may offer you access to our Services. We will share Personal Data with your employer or organization. Your employer or organization can review and manage your use of such enterprise Services.
• For external processing. We provide personal information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include marketing partners, third party hosted services providers, and similar partners. It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.
• For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Spendly if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable Terms of Use, including investigation of potential violations.
  • detect, prevent, or otherwise address fraud, security or technical issues.
  • protect against harm to the rights, property or safety of Spendly, our Users or the public as required or permitted by law.
  We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
• Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Spendly itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.
• Non-Personal and Aggregate Site Use Information. Spendly may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such de-identified information publicly and to third parties, or to Spendly Partners under agreement with us.
• We disclose your Personal Information for a business purpose to the following categories of third parties:
  • Our affiliates;
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
  • Service providers and other third parties we use to support our business, including without limitation those performing core services (such as credit card processing, customer support services, customer relationship management, accounting, auditing, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services.
  • Commercial providers;
  • Enterprise accounts such as your employer or organization.

We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are over broad, vague or lack proper authority, but we do not promise to challenge every demand.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our services and Web apps. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or Web apps, or parts of our Services and/or Web apps.

Our retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of Web apps and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

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We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Your Rights and Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

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Privacy Rights Specific to Californians

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

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Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

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● Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  

● Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology     environment to another service provider’s servers or information technology environment.

● Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

● Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.

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Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

1. Submit a request via email to matthew@getspendly.com.

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You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

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Our Response to Your Request

‍ Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.  

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We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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‍In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

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We may deny your deletion request if retaining the information is necessary for us or our service providers to:

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1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

3. Debug products to identify and repair errors that impair existing intended functionality;

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; 8. Comply with a legal obligation; or

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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Rights Specific to European Union Residents

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”),corresponding legislation in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

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1. The right to be informed. You are entitled to be informed of the use of your Personal Data. This Privacy Policy provides such information to you.

2. The right of access. You have the right to request a copy of your Personal Data which we hold about you.

3. The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.  

4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers  and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.

5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data at any time.  

6. The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.

7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to  be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.

8. The right to lodge a complaint with a supervisory authority.

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You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

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If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

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In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Rights Specific to Canadians

The Personal Information Protection and Electronic Documents Act (PIPEDA), provides you with certain rights in connection with Personal Information you have shared with us. If you are a resident of Canada, you may have the following rights:

Individual Access. You have the right to access the personal information that we hold about you. Under certain circumstances, we maybe prohibited from fulfilling your request. The response we provide will explain the reasons we cannot comply with a request, if applicable.

Right to Correction. You have the right to challenge the accuracy and completeness of the information we have about you, and have that information amended as appropriate.

Exercising Your Rights

If you are a Canada resident who chooses to exercise your rights, you can submit a request to the Sr. Compliance Analyst via email to privacy@Spendly.com.

Our Response to Your Request

Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

We will respond to your request within thirty (30) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

‍In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

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Our Opt-in/Opt-out Policy

‍By providing an email address on the Spendly Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information. For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

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We currently provide the following opt-out opportunities:

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1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a Spendly Partner to unsubscribe from the service.    

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2. At any time, you can contact us through matthew@getspendly.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.  

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Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

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Your Ad Choices

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‍As described above, we or third party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising(also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. Spendly is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.

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The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not Spendly. Spendly does not control or operate these tools or the choices that advertisers and others provide through these tools.

Third Party Links

The Sites may contain links to webpages operated by parties other than Spendly. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. Spendly strongly recommends that each User review the third party's terms and policies.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.

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Personal Data and any additional information submitted may be used globally in connection with employment, business processes within Spendly, or communicating with our Spendly Partners. Therefore, Personal Data may be transferred to such entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

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If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

EU-U.S. PRIVACY SHIELD INVALIDATION

On July 16, 2020, the Court of Justice of the European Union (CJEU) issued a judgment declaring as “invalid” the European Commission’s Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States. I: In face of this decision, Spendly has decided to withdraw from the EU-U.S. Privacy Shield Framework. Nevertheless, it will continue to apply the Privacy Shield Principles to personal data that it had received in reliance upon Privacy Shield and affirm to the Department of Commerce on an annual basis its commitment to apply the Principles to such data.

Additionally, while the Court of Justice of the European Union (CJEU) invalidated the EU-U.S. Privacy Shield Framework, the CJEU validated the use of Standard Contractual Clauses (SCCs). Spendly is committed to the use of SCCs. SCCs are a commonly used mechanism for transatlantic data transfers. They are standard sets of contractual Terms of Use which the sender and the receiver of the personal data both sign up to. They include contractual obligations which help to protect personal data when it leaves the European Economic Area (EEA) and the protection of GDPR. This method does make it possible in practice to ensure compliance with the level of protection required by EU law.

How we protect personal data

Spendly maintains administrative, technical and physical safeguards designed to protect the User's Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to Spendly employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

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If Spendly collects account information for payment or credit, Spendly will use the information only to complete the task for which the account information was offered.

Children

The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at matthew@getspendly.com If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Direct Marketing and "Do Not Track" Signals

Spendly does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

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California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request to matthew@getspendly.com California users may request further information about our compliance with this law by contacting us at matthew@getspendly.com or by writing to us at the address listed in the “How to Contact Us” section.

Spendly Partners

Spendly customers (“Spendly Partners”) engage us to deliver Services to their employees, customers and other users. Partner Information, Information about our Partner’s Contacts and Archival Information (each defined below) are governed by this Privacy Policy, the Spendly Terms of Use and any other services agreements between Spendly and the applicable Partner.

• Spendly Partner Information. We collect information about individuals within our Spendly Partners organization (“Partner Information”). Partner Information may include information related to the Partner’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Partner Information to support the Partner account, maintain our business relationship with the Partner, respond to Partner inquiries, or perform accounting functions. Spendly Partners may update personal information and password by logging into the Spendly Platform and updating their account. Spendly Partners may contact Spendly support in order to delete their Personal Data. In some cases, we may not be able to delete Partner Information, and in such cases we will tell you why.
• Information about our Partners’ Contacts. We collect information about any contacts, such as employees, customers, and others, that may be uploaded into the Spendly Platform (“Information about our Partners’ Contacts”). Information about our Partner’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Partner’s Contacts for the purposes of providing Services to such contacts. Spendly Partners may update or delete Information about their contacts in the Spendly Platform. Spendly Partners may also contact Spendly support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
• Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Spendly Partners. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our Spendly Partners and the third parties they correspond with. We do not control or monitor the information our Spendly Partners collect and store through our services, or their privacy practices or policies. It is our Partner’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Partner’s communications and use of our services. Our Partner’s privacy policies or practices apply to Archival Information, the purposes for which the Partner collects Archival Information, how the Partner may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Partner in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Partner.
• Automatically Collected Information. We collect information automatically about how our Spendly Partners use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Spendly Partners with certain customized features. We may use Automatically Collected Information to tell us how our Spendly Partners use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.
• Whenever You interact with our Web app, we automatically receive and record Information through our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” Information, the type of browser and/or device you are using to access our Web app, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features on Web app are visited and by how many people. Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a User's computer hard drive or within a browser. They enable our Web app to remember Information about the User's visit to our Web app. On mobile websites and mobile applications, we use device IDs and / or Advertising IDs in a similar manner to which we use cookies. You can find more information about cookies at: www.allaboutcookies.org or www.youronlinechoices.eu. 
• The types of cookies we may use include but are not limited to:  
• Session Cookies. These are cookies which expire once you close your web browser.
• Persistent Cookies. These are cookies which stay on your desktop or mobile device for a specific period of time or until you delete them from your device.
• First-party cookies. These are cookies that are set by our Web app when you visit, or by a third party at our request.
• Third-party cookies. These are cookies that are set by a third-party other than that of the website you are visiting. If you visit Web app and another party sets a cookie through that website this would be considered a third-party cookie.
• Essential cookies are sometimes called “strictly necessary” because without the use of this type of cookie ye cannot provide many of the services that you need to use our Web app. They are usually only set in response to actions made by you related to a request for Services or to use various features on our Web app. For example, essential cookies help remember your preferences, such as setting your privacy preference or logging in, as you move around our Web app and use its features.
• Analytical cookies are as the name implies used to analyze and track Information about your Web app visits so we can review performance and use that Information to better improve our Web app, its features, Services, and Content.  The Information these cookies collect is useful for possible future services, monitoring, and marketing. 
• Functionality or preference cookies let us operate various features on our Web app according to Your preferences. These cookies help us to provide you with our Services based on Information you provide to us, such as your username, your preferred language choice, and how you have customized our Web app features. These preferences are recalled and the next time you visit Web app you won’t have to set them again. They may be set by us or by third party providers whose services we have added to our pages and they help our Web app function properly according to your preferences.
• Targeting or marketing cookies are cookies that are placed by third-party advertising platforms or networks in order to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities. This is known as behavioral, tracking, or targeted advertising on a social media platform or website. The Information is then used to show you advertisements that you may be interested when you visit other websites or social media platforms. For example, these cookies remember which browsers have visited the website. If you do not allow these cookies you will still see basic advertising on your browser but that advertising will be general in nature and not specific to your interests.
• You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Please refer to your devices settings to make those changes.
• We may receive confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve Web app, features, Content, and Services.
• We may use this data to customize Content for You that We think You might like, based on Your usage patterns. We may also use it to improve our Web app – for example, this data can tell us how often Users view particular Content or use a particular feature or Service offered though our Web app, and we can use that knowledge to make improvements.

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Program Analytics                                We use multiple web analytics tools provided by service partners such as Google Analytics to collect Information about how you interact with our Web app and software, including what pages you visit, what site you visited prior to visiting our Web app, how much time you spend on each page, what operating system and web browser you use and network and IP Information. We use the Information provided by these tools to improve our Services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our Web app or use our Services. Each cookie cannot be used by anyone other than the service provider (example: Google for Google Analytics). The Information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. The Information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by utilizing settings in your browser or third-party tools. You can opt-out of making your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing Information with Google Analytics about visits activity. For more Information on the privacy practices of Google, please visit the Google Privacy & Terms web page:  https://policies.google.com/privacy.

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Do Not Track Signals and GPC                                   Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. We do not generally alter our practices when We receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.  Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences regarding ad trackers. If you do choose to set up GPC, it may impact the functionality of your use of our Web app and Service, but we honor the GPC signal automatically in your cookie preferences.

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Processing of Your Data

We will not (a) modify your data, except for use with our Web app or when expressly permitted in writing by you, (b) disclose your data except as compelled by law or as expressly permitted in writing by you, or (c) access or use your data except to provide the application and prevent or address service or technical problems, or at your request in connection with customer support matters. In addition, we will comply with all applicable laws in providing the application to you. We agree to maintain the confidentiality of any data accessible by us or our Web app indefinitely following the expiration or termination of this Agreement. 

Artificial Intelligence (AI) Disclaimer

This section outlines our use of Artificial Intelligence (“AI”) and machine learning technologies. By using our Web app, you acknowledge and agree to the practices described herein.

1. How We Use AI:

We may leverage AI and machine learning through our Web app and our or third party software, for various purposes to enhance your experience, improve our services, and operate more efficiently. These uses may include, but are not limited to:

Personalization: Tailoring content, recommendations, and features based on your preferences and usage patterns.

Service Improvement: Analyzing aggregated and de-identified data to identify trends, improve functionality, and develop new features.

Security & Fraud Prevention: Detecting and preventing malicious activities, unauthorized access, and fraudulent transactions.

Content Moderation: Assisting in identifying and moderating inappropriate or harmful content in accordance with our terms of service.

Customer Support: Powering chatbots (whether online text chatbots or verbal bots that talk to someone that is on a phone, electronic, or mobile device) or intelligent assistants to provide faster and more efficient support.

Data Analysis & Insights: Extracting insights from data to optimize our operations, marketing, and business strategies.

2. Data Used by AI:

Our AI systems may process various types of data, including:

Information you provide directly: Such as your profile information, communications, content you submit, and other Personal Data.

Automatically collected data: Such as usage data, device information, IP addresses, location data, and other Personal Data.

Publicly available information: In some cases, AI models may be trained on or process publicly accessible Personal Data.

We endeavor to use anonymized or aggregated data where possible for AI training and analysis to minimize the use of personally identifiable information.

3. Limitations and Accuracy of AI:

While we strive to develop and implement AI systems that are accurate, fair, and reliable, it's important to understand the inherent limitations of AI:

Errors and Inaccuracies: AI models, by their nature, may occasionally produce outputs that are incorrect, incomplete, or based on flawed assumptions. Also, if the error is made by a typo or inaccurate information you input, AI will not necessarily be able to correct your error.

Bias: AI models are trained on data, and if that data contains biases, the AI may perpetuate or even amplify those biases. We are committed to mitigating bias in our AI systems through careful data selection, model design, and ongoing evaluation.

Contextual Understanding: AI may not always fully grasp the nuances of human language, intent, or complex real-world situations, potentially leading to misinterpretations.

No Substitute for Human Judgment: Any decisions or actions taken based solely on AI outputs should be critically reviewed. Our AI systems are often designed to assist, not replace, human judgment and oversight.

4. No Automated Decision-Making with Legal or Significant Effects (where applicable):

Unless explicitly disclosed and with your explicit consent where required by law, we do not use AI for automated decision-making that produces legal effects concerning you or similarly significantly affects you. 

5. Data Security and Privacy:

We implement appropriate technical and organizational measures to protect the data processed by our AI systems, in accordance with our Privacy Policy. This includes data encryption, access controls, and regular security audits.

6. Your Choices and Rights:

Your rights regarding your personal data, as outlined in the "Your Choices and Rights" section of this Privacy Policy, apply to data processed by our AI systems. Depending on your jurisdiction, you may have rights related to access, rectification, erasure, restriction of processing, and objection to processing, even when AI is involved.

7. Changes to this AI Disclaimer:

We may update this AI Disclaimer from time to time to reflect changes in our AI practices or legal requirements. We will notify you of any material changes by posting the updated disclaimer on our website or through other appropriate communication channels. Your continued use of our Web app and Services after such modifications constitutes your acknowledgment and acceptance of the revised AI Disclaimer.

Your Choices and Rights

You have the following choices and rights concerning your personal information. Depending on where you live and the applicable privacy laws, these rights may include:

Access and Update: You may access and update your personal Information.

Opt-Out: You can opt out of receiving SMS or email communications from us at any time by following the instructions provided in those messages.

Access: You can request to see the personal information we hold about you.

Correction: You can ask us to correct any inaccurate or incomplete Personal Data we have.

Deletion: You can request that we delete your Personal Data in certain circumstances.

Opt-Out of Marketing: You can opt out of receiving marketing communications from us at any time.

Do Not Sell/Share: You have the right to direct us not to "sell" or "share" your Personal Data. 

We treat Partner Information, Information about our Partner’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Spendly Partners, subject to the terms of the Spendly Terms of Use and any other service agreement between Spendly and the Partner. We do not share Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Partner, as may be necessary to provide services to the Partner, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Partner, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, Spendly Partners, channel partners or service providers.

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We will retain Partner Information we process on behalf of our Spendly Partners for as long as needed to provide services to our Partner, or for the period of time requested by a particular Partner.

Social Media, Posts, Texts, Forums and Profiles

Each User agrees that we may make available through our Web app third party sites, or the Services certain forms of media either now existing or to be created in the future (for example, social media, message boards, applications, metaverses, augmented reality social networks, chat functionality, videos, pictures, images, profile pages, text messaging and blogs) to which Users may be able to post Content. Please note that any Content, we, rss providers, outside third parties, or Users provide on these various forms of media may become public, and may be available to visitors to Our Web app, third party sites, our Services, and to the general public, including without limitation the ratings and reviews that accompany any pages on our Web app or third party sites. We urge Users to exercise discretion and good manners when disclosing any of their personal or financial information. Additionally, as stated in our Terms of Use, you give us the free unlimited right to use any comments or Feedback you give us, which we may use for any purpose whatsoever, including but not limited to reproducing, modifying, disclosing, exhibiting, displaying, transforming, creating derivative works, and distributing the Feedback to others in social media, print, audio, or any other form of communication without limitation.

EACH USER AND CUSTOMER AGREES THAT WE SHALL NOT BE RESPONSIBLE FOR ANY LOSS CAUSED BY OUR USE OR THE USE BY ANY UNAUTHORIZED PERSON OR ENTITY, OF ANY CONTENT THAT USERS DISCLOSE THROUGH OUR WEB APP OR THE USE OF OUR SERVICES.   

California Online Privacy Protection Act Compliance                                                                                               As part of the California Online Privacy Protection Act, all Users of our Web app may make any changes to their information at any time by logging into their account and changing their information. We will not distribute their personal Information to outside parties without their consent.

Children Online Privacy                                                                                                                                        Anyone under 18 years of age should not access our Web app and should not use our Services. Our Web app and Services are not intended for those under 18, and we will not knowingly collect any information from anyone under the age of 18. If we discover that we have collected any personally-identifying information from a child or person under the age of 18, we will promptly remove that information from our database.

Security Not Guaranteed                                                                                                                                          We use reasonable organizational, technical, and administrative measures to protect each User’s personal Information and PII under our control. However, we cannot guarantee 100% percent protection and security of such personal Information.  Please do not email or text Us credit card information and/or other sensitive personal or financial information. 

Security
We are committed to ensuring that PII is secure. All non-financial Information and Content provided to us is stored on our secure servers. In order to prevent unauthorized access or disclosure, we have taken all reasonable steps and put in place suitable safeguards to secure the Information we collect from Users online. 

Unfortunately, the transmission of Information via the internet is not completely secure. Although we will use reasonable efforts to protect each User’s personal data, we cannot guarantee the security of their data transmitted to our Web app; any transmission is at the risk of each User. Once we have received PII, we will use the necessary procedures and security features to try to prevent unauthorized access. We will take all reasonable steps necessary to ensure that PII and data is treated securely and in accordance with this P​rivacy P​olicy.

Links to Third Party Sites         Our Web app may contain links to other third party sites. However, once Users have used these links to leave our Web app, they should note that we do not have any control over the third party site being visited. Therefore, we cannot be responsible or liable for the protection and privacy of any Information provided or which is obtainable when visiting those third party sites which are not governed by this Privacy Policy or our Terms of Use. To the extent that you access or use the Service through or on another third party site or application, then the privacy policy of that third party site or application will apply to your access or use of that site or application. We encourage our Users to read the privacy statements of other third party sites or applications before proceeding to use them. 

Users may be permitted to export, transfer, upload, or archive their data and other Information from our Web app into various external cloud storage locations. User understands and agrees that we have no control over the security or privacy policies of those external connectors, integration systems, websites, or third party software applications and access, visibility, security is controlled by the client administrator(s).  User understands the risks and agrees to hold us harmless from any claims related to any loss sustained related in any way to the export, transfer, upload, or archive of their data and other Information.

Access to and Control Over Information We Send Users                                                                                    From time to time we may send Users emails about special offers, discounts, products, or additional Services we feel they may find useful. Users can opt out of receiving our emails by clicking the unsubscribe button in the email. 

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

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How to Contact Us

Please contact us if you have any specific questions or would like to access your personal Information, request that your personal Information be removed from our data base, or to have your Information updated, changed or modified. You can contact us via email or phone or by writing to us at the address below:

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Send e-mail to: matthew@getspendly.com 

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