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Privacy Policy

Last Updated: October 28th 2022

Spring, operating as a registered company Datablock AS and its affiliates (“Spring”, “we”, “our”, and/or “us”) values the privacy of individuals who use our apps, websites, or services that link to this Privacy Policy (collectively, our “Services”). If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “personal data” means any information relating to an identified or identifiable individual. This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal data from users of our Services. By using our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service.

INFORMATION WE COLLECT
We may collect a variety of information from or about you or your devices from various sources, as described below.
If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us
Registration and Profile. When you register for an account to use our Services, for instance to make an investment/contribution using Spring, we ask you for your personal data, which may include your email address, user name, digital wallet number, public information from your digital wallet and additional information provided when making an investment/contribution (if relevant). We will also collect any information you provide in response to screening questions required by our customers before you can make an investment/contribution using Spring.

Know your customer (KYC) identity verifications. Some companies/projects might require you to do a “Know your customer” identify verification, before making investments/contributions to their company/project. These requirements are set by the company/project and not by Spring. If you are required to carry out a “Know your customer” identity verification, the information that you provide (e.g. copy of ID document, photo, name, birth date, nationality, verification photo/video) will be stored by Spring on behalf of the company/project. The company/project requiring such verification will have access to that information.

Communications. If you contact us directly, we may receive additional personal data about you. For example, when you contact us via a contact form, email, or other means, we will receive your first name, last name, email address, as well as the content, date, and time of your message. If you contact us from third party sources, like Telegram and Intercom, we will receive your user name, as well as the content, date and time of your message. If you subscribe to our newsletter, we will receive your name and email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform such as LinkedIn or Recruitee we will collect the information you make available to us through such third-party platform.

B. Information We Collect When You Use Our Services
Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, including but not limited to the pages or other content you view, the searches you conduct, and the dates and times of your visits.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, applications, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect personal data using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on our Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, hidden tags, and similar technologies (collectively "Cookies") to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect personal data.

  • Strictly Necessary Cookies. Some Cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of Cookies.
  • Functional Cookies. Functional Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region.
  • Analytical or Performance Cookies. We also use Cookies for website analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics. Google uses the data collected to track and monitor the use of our Service. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en . We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245 . These providers may also collect information about your use of other websites, apps, and online resources.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect:

  • To provide, maintain, debug, improve, and enhance our Services;
  • To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
  • To understand and analyze usage patterns;
  • To process your job application;
  • To communicate with you, provide you with updates and other information relating to our Services and its promotions, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • To send you SMS, calls, or push notifications;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • To aggregate and otherwise de-identify for other business purposes;
  • To facilitate transactions and payments;
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
    For other purposes for which we provide specific notice at the time the information is collected.