Privacy Policy

Effective Date: June 28, 2022
Last Updated on: June 28, 2022


This privacy policy (“Policy”) explains how Spendflo, Inc. or any of its affiliates or subsidiaries. (“We”, “Us”, “Our”) Processes Personal Data collected from You.

1. DEFINITIONS

1.1. “Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.

1.2. “End-User” means any person or entity with whom the Subscriber interacts using the Service(s).

1.3. “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.4. “Process means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.5. “Processor” means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller.

1.6. “Service(s)” shall have the meaning ascribed to it in the Terms of Use. 

1.7. “Subscriber” means the natural or legal person that has subscribed to the Service(s) by agreeing to the Terms of Use.

1.8. “Terms of Use” means the binding contract between Us and You which governs the access and use of the Service(s) by You available at https://www.spendflo.com/terms-conditions

1.9. “Website(s)” means the websites that We operate.

1.10. “You” and “Your” means an identified or identifiable natural person whose Personal Data We process as a Controller.

2. PERSONAL DATA COLLECTED BY US

2.1. You directly provide Us with most of the data We collect. We collect Personal Data from You directly as follows: a) When You subscribe for any of Our Service(s) by agreeing to the Terms of Use, We collect sign-up and account information including Your name and e-mail address; b) When You submit web forms on Our Website(s) or as You use interactive features of the Website(s), including providing feedback or suggestions, making requests, or participation in surveys, contests, webinars, events, podcasts, promotions, sweepstakes, requesting customer support, or otherwise communicating with Us; c) When You provide testimonials, forms or information to Us in other contexts;

2.2. We may also receive Your Personal Data indirectly as follows: a) from third party sources like marketing lists, databases and social media but only where We have checked that these third parties either have Your consent or are otherwise legally permitted or required to disclose Your Personal Data to Us; b)When You download and/or use the Service(s), We automatically collect information on the type of device You use, and the operating system version, to perform Our agreement with You; e) When You use or view Our Website(s), information is collected via Your browser’s cookies as described in clause 9 herein; f) We may also collect or receive Your Personal Data from other sources such as Our business or channel partners through whom You create or access Your Account, publicly available sources, email add-ons and/ or through the combining of information We obtain from third parties along with the Personal Data You provide to Us; or g) When You authorize Us to connect with a third-party service, We will access and store Your Personal Data that the third-party service makes available to Us, which may include Your email address, location or profile information.

2.3. The Website(s) includes social media features and widgets that are either hosted by a third-party or hosted directly on the Website(s) and Your interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. You should check Your privacy settings on these third-party services to understand and change the information sent to Us through these services.

3. LEGAL BASIS FOR PROCESSING (EEA REGION)

3.1. If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

3.2. We will normally collect Personal Data from You only where We need it to perform a contract with You, where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under Clause 13.

4. PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED

We Process Your Personal Data to: a) facilitate Your access to the Website(s) and Service(s); b) process and complete payment transactions; c) provide customer service and support; d) send You communication on Your use of the Service(s), updates on Our Terms of Use or other policies; e) send You communication on new features in the Service(s) or new service offerings; f) conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve Our Service(s) and facilities in order to enhance Your relationship with Us or for Your benefit, or to improve any of Our Service(s) for Your benefit; e) Organise events or for other marketing/ promotional activities; f) investigate and prevent fraudulent transactions, unauthorized access to the Websites and Service(s), and other illegal activities; g) personalize the Websites and Service(s); and for other purposes for which We obtain Your consent.

5. SHARING OF PERSONAL DATA

5.1. You acknowledge that We will share Your Personal Data with Our group companies and third-party service providers so that they may offer You Our Service(s) and/or to send information or updates on the Service(s) if You are a Subscriber.

5.2. When We Process Your order where You are a Subscriber, we may send Your Personal Data to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.

5.3. We share Personal Data with Our third-party service providers that host and maintain the Our Website(s), applications, backup, storage, payment processing, analytics and other services. These third-party service providers may have access to or Process Your Personal Data for the purpose of providing these services to Us.

5.4. We may share Your Personal Data with third-party providers who assist Us in marketing and promotions in compliance with applicable laws.

5.5. We may be required to disclose Your Personal Data in response to: a) lawful requests by public authorities, including to meet national security or law enforcement requirements and/or b) subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims.

5.6. We may also share Personal Data to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our Terms of Use, or as otherwise required by law.

6. INTERNATIONAL TRANSFER

6.1. We mainly Process Personal Data in the United States of America. However, We may transfer Personal Data outside the United States of America for the purposes referred to in Section 4. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.  

6.2. If You are a resident of the European Economic Area and when Your Personal Data is processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

7. RETENTION OF PERSONAL DATA

7.1. We retain the Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.

7.2. In the absence of a need to retain Personal Data under Section 6.1. above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

8. SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us immediately as described in this Policy.

9. YOUR RIGHTS

You are entitled to the following rights:

9.1. You can request Us for access, correction, update or request deletion of Your Personal Data.

9.2. You can object to the Processing of Your Personal Data, ask Us to restrict processing of Your Personal Data or request portability of Your Personal Data.

9.3. You have the right to opt-out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails We send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact Us.

9.4. Similarly, if We have collected and processed Your Personal Data with Your consent, then You can withdraw your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

9.5. You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority.

9.6. If You seek access to, or wish to correct, update, modify or delete Your Personal Data that We process, please contact Us at the details provided in clause 12. We respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

10. COOKIE POLICY

10.1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how our Website(s) are being used or how effective Our marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You.

10.2. Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

10.3. Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.  

11. PRIVACY OF CHILDREN

11.1. We recognize the importance of children's safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to us at the email address provided in clause 12.

12. NOTICE TO END-USER AND OTHER EXCLUSIONS

12.1. Our Service(s) are intended for use by enterprises. Where the Services are made available to an End-User through a Subscriber, that enterprise is the Controller of the End-User’s Personal Data. For example, suppliers who are invited by Our Subscribers to interact with them through the Service(s) would be End-Users. In such a case, the End-User’s data privacy questions and requests should be submitted to the Subscriber in its capacity as the End-User’s Controller. If the End-User is an individual who interacts with a Subscriber using Our Services, the End-User will be directed to contact Our Subscriber for assistance with any requests or questions relating to their Personal Data. We are not responsible for Subscribers’ privacy or security practices which may be different from this notice. Subscribers to Our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Our Services by End-Users.

12.2. Our Website(s) contain links to other websites. Our Policy applies only to our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

12.3. This Policy does not apply to aggregated information which summarises statistical information about groups of members, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.

13. RESTRICTIONS ON THE USE OF GOOGLE USER DATA:

Notwithstanding anything else to the contrary contained in this Privacy Policy, any Google
User Data that is accessed by Us through Restricted Scope shall be subject to the following
restrictions:

The Services will only use access to read, Gmail message bodies, metadata, headers and
settings to provide a web email client that allows users to compose, send, read and process
emails. We will not transfer the Google User Data unless it is a) necessary to provide or
improve user-facing features that are prominent from the Spendflo application’s user
interface b) to comply with applicable laws, or c) a part of a merger, acquisition or sale of
Spendflo’s assets. All other use or transfer of Google User Data is prohibited including
serving advertisements. The Google User Data is prohibited from human interaction unless

  A. We have first obtained the google user's affirmative agreement to view specific messages,

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  B. It is necessary for security purposes (such as investigating a bug or abuse);

  C. It is necessary to comply with applicable law; or

  D. The use is limited to internal operations and the data (including derivations) have
been aggregated and anonymized.

Spendflo application’s access, use, storage, transfer to any other application, of any
information received through the Google API shall comply with the Google API Services
User Data Policy
including the Limited Use Requirements.

14. CONTACT INFORMATION

You may contact us if You have any enquiries or feedback on Our personal data protection policies and procedures, or if You wish to make any request, in the following manner:

Kind Attention: Ajay Vardhan

Email Address: ajay@spendflo.com

Address: 2261 Market Street #4821, San Francisco, CA 94114, United States

15. CHANGES TO THE POLICY

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.

Additional Disclosures for California Compliance (US) - Applicable, if and when, We meet the conditions stipulated for applicability of California data privacy law

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.

CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

Commercial information, such as products or services history and purchases.

For more information on information we collect, including the sources we receive information from, review this Privacy Policy. We collect and use these categories of personal information for the business purposes, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.
  • To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.