Finally, please note that some of the abovementioned personal information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal information and further use it for internal and external purposes, including, without limitation, to analyze and improve services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings). “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

To the extent that personal information collected under to this Privacy Policy is subject to the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing personal information are:

- Your consent,

- We have a contractual obligation or processing is necessary in order to take steps prior to entering into a contract,

- We have a legal obligation and/or

- We have a legitimate interest.

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

- Security: We have implemented appropriate technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

- Retention of your personal information: Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

We share your personal information as follows:

(a) With our service providers and business partners and other third parties, including, without limitation:

- With cloud service providers for hosting purposes;

- With websites and web content creation platforms in order to help us manage our Website;

- With email providers, marketing, CRM, other similar tool providers; and

- With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.

(b) With our staff and other entities within our group.

© With your manager and any other authorized person within the company you work (if the use of the Service is based on our engagement with your company).

We may also share your personal information as follows:

- To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Aspiro, our Services, customers, employees, property, and the public;

- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we may disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events;

- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we may transfer, disclose or assign your personal information in connection with the foregoing events; and/or

- Where you have otherwise provided your consent to us for sharing or transferring your information.

4. YOUR PRIVACY RIGHTS

This section also covers how to delete your account.

Rights: You can exercise your rights by contacting us at hello@letsaspiro.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Deleting your account: Should you ever decide to delete your account, you may do so by emailing hello@letsaspiro.com. If you terminate your account, any association between your account and personal information we store will no longer be accessible through your account.

Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK ASPIRO EMAILS” to hello@letsaspiro.com. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you may use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

5. USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any personal information to us without involvement of a parent or a guardian. In the event that we become aware that you provide personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at hello@letsaspiro.com.

6. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

8. ANALYTIC TOOLS

Google Analytics

The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Microsoft Clarity & Zipy

The Website uses MS Clarity & Zipy in order to better understand our users’ needs and to optimize this service and experience. These are technology services that help us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. They may uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Both the tools store this information in a pseudonymized user profile & do not allow any sensitive inputs by users (e.g. username, password etc.) to be visible.

Neither these companies nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see MS Clarity’s privacy policy at https://clarity.microsoft.com/terms and Zipy’s privacy policy at https://docs.zipy.ai/legal/privacy-policy. You can opt-out to the creation of a user profile, storing of data about your usage of our Website and use of tracking cookies on MS Clarity as per instructions given under FAQs on this link and on Zipy using the information provided within their Privacy Policy in the link above. We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

9. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at hello@letsaspiro.com.