Privacy Policy

EFFECTIVE DATE: June 1, 2018

General Information

PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.

This Privacy Statement and Notice of Privacy Practices (“Privacy Policy”) sets forth the privacy practices of Spur and its affiliates, subsidiaries, agents, representatives, successors and assigns (collectively “Spur”) located in the United States. For the purpose of the following terms, references to “We”, “Us” and “Our” include Spur and its affiliates, subsidiaries, agents, representatives, successors and assigns. We create a marketplace for efficiently connecting businesses and workers that match one another’s availability and need. These offerings are defined under this Privacy Policy collectively and individually as Our (“Services”).

This Privacy Policy is applicable to all data collection by Spur and shall apply to the user’s (“You” or “Your”) use of this Web site, Your use of any affiliated third party Web sites that may contain a link to this Privacy Policy, to any pages, facilities, services, or capabilities accessible on or by any top-level Spur domain owned by Us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a “Site” and collectively the “Sites”), and the Services.

This Privacy Policy shall apply strictly to customer information collected in the United States. This Privacy Policy describes how Spur treats Your use of the Sites, including the collection, storage, transfer, sharing, disclosure and handling of Your personal information and Your use of Our Services.

By using Our Services, You acknowledge that You have read this Privacy Policy and consent to Spur’s privacy practices as described in the Privacy Policy, including Our use and disclosure of Your personal information for the purposes described below. You further affirm Your consent by submitting content or materials to or through Our Services.

We take the privacy of Your personal information seriously. If You have any questions or concerns about this Privacy Policy or Your personal information please contact Us directly at the email or mailing address listed in Section 2 (Contact and Electronic Communication).

Changes and Updates to this Privacy Policy

Spur reserves the right to revise or update this Privacy Policy at any time, and You agree to be bound by those revisions or updates. Spur will notify You of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Effective” date on the Sites. Your use of the Sites thereafter constitutes Your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. This Privacy Policy is incorporated as part of the General “Terms of Service” that apply with respect to Your use of the Sites and Our Services, which We define below in this Privacy Policy. If You do not agree to the terms and conditions of this Privacy Policy, including having Your personal information used in any of the ways described in this Privacy Policy, please do not provide Us with Your information or use the Sites.

Contact and Electronic Communication

By using Our Services or providing Your personal information to Us, You agree that We can communicate with You electronically regarding any legal, regulatory, technical, security, privacy and any administrative or consumer notification obligations that may be related to Your use of the Services. If You have any questions about this Privacy Policy or about Our Services related to the Privacy Policy, You can contact Spur by e-mail at Legal@SpurJobs.com.

You may also contact Us at:

Spur, Inc.
Attn: Legal
P.O. Box 107
Huntsville, Alabama 35804

Types of Information Collected and How it is Collected

The types of information We collect from You when You access Our Site or use Our Services are listed below. Spur may share both Your Information with its affiliates, subsidiaries, partners and other third parties, such as third parties who help operate the Sites and related databases and Our mobile applications. Use of such third parties is subject to the terms of use and privacy policies of those third parties. Spur is not responsible for the privacy practices of any other Web sites or third parties. You should review the terms of use and privacy policies that are posted on by those third parties, before using any services they provide. Spur accepts no liability for any information, products, advertisements, content, services or software accessible through these third party websites or for any action You may take as a result of linking to any such website. We collect information directly from You, through use of Our Sites, mobile applications, or Services or from third parties that work with Spur to deliver Our Services.

Personal Information We Request From You and Background Checks

Certain areas of the Sites (e.g. creating a user account whether as a Worker or Workplace (as such terms are defined in the Terms of Service)) will require You to provide personal information to Spur. That personal information may include Your name, phone number, e-mail address, mailing address, zip code, username, password, credit card information, social security number, birth date, criminal history, bank account information, citizenship status, previous work experience, education background, and federal employment identification number. As part of the hiring or account registration process, Spur or its affiliates may require You to provide a copy of Your driver’s license, passport, military ID, or other personal identification card.

We or Our designated agents or representatives may request background information about You, including available personal information, from a consumer reporting agency in connection with Your request to use the Site for work purposes. The Fair Credit Reporting Act (the “FCRA”) defines such a report, including investigative consumer reports as defined under the FCRA, as a “Consumer Report”, and all inquiries are limited to information that affects Your performance of potential Jobs (as such term is defined in the Terms of Service) through Our Site. All requests are conducted in accordance with applicable laws, including the FCRA. We use an outside agency for this screening: Inflection Risk Solutions, LLC dba GoodHire P.O. Box 391403 Omaha, NE 68139, Phone: 1-888-906-7351 Fax: 650-362-1933. As a result, GoodHire may obtain a Consumer Report on You as a user of the Site.

**Authorization and Release:** Pursuant to the United Stated Fair Credit Reporting Act, You hereby authorize Spur and its designated agents and representatives to conduct a comprehensive review of Your background through a Consumer Report and/or an investigative consumer report to be generated for prescreening for Jobs through Our Site. By accepting this Privacy Policy, You acknowledge and agree that You have carefully read and understand this disclosure for the procurement of Consumer Reports. You also understand that information contained in Your account or otherwise disclosed by You before or during Your use of Our Site, if any, may be used for the purpose of obtaining Consumer Reports and/or investigative consumer reports. By accepting this Privacy Policy, You authorize law enforcement agencies, learning institutions (including public and private schools and universities), information service bureaus, credit bureaus, record/data repositories, courts (federal, state, local, or international), motor vehicle records agencies, Your past or present employers, the military, and other individuals and sources to furnish any and all information about You that is requested by the consumer reporting agency. You certify the information that You provide in order for Spur or its designated agents or representatives to obtain a Consumer Report is true and correct and will be valid for any reports that may be requested by or on behalf of Spur.

In addition, some Workplaces may have additional background check requirements that they may require of You before accepting You as a Worker. Such Workplaces may share the information they collect about You through their own background checks with Us and other third parties, including, without limitation, government and regulatory agencies, according to the terms of the specific Workplace’s background check. We do not control the Workplace’s criteria for collecting or sharing of the information the Workplace collects about You through its separate background checks; please carefully review the terms and conditions of any Workplace’s separate background check required of You.

While it is Your choice whether to provide the requested information or not, We cannot provide certain Services You request if You do not provide the requested information. By submitting this personal information to Spur, You agree that Spur may use the information in accordance with this Privacy Policy, for example to provide You with the Services, match Workers with contact opportunities, adapt and improve Spur services to better suit Your needs and to meet legal, regulatory, or contractual requirements relating to the services provided to You. If You do submit such personal information to Spur, Spur may share that information with third parties as set forth in this Privacy Policy, in addition to using that information for the purposes for which it was submitted by You.

Spur may also use this personal information in other ways, such as to provide You with information about Services and offers that may be of interest to You, to seek follow-up from You about Your experiences with Spur or as otherwise disclosed to You at the point of collection. Where required, Spur will seek Your express consent to send such messages, including when sent by e-mail or other type of commercial electronic message. This consent is sought by Spur, P.O. Box 107, Huntsville, Alabama 35804. You may withdraw Your consent by using the “unsubscribe” link located at the bottom of such messages You receive from Spur, or by contacting Spur at the email or postal address listed in Your applicable user agreement.

Spur may share Your personal information with its affiliates, subsidiaries and partners and with other third parties. Additionally, to the extent required by applicable federal or state law, Spur may be required to disclose Your personal information in response to lawful requests by public authorities, including to meet regulatory, national security, or law enforcement requirements. By submitting personal information to Spur, You give Spur permission to receive it, review it, edit it, store it and use it for the purposes described in this Privacy Policy.

Other Types of Information We Collect

Spur also gathers certain information about Your work preferences, how You use Services, Your availability, the use of Spur’s Sites, including the number of unique visitors, the frequency of visits, how users interact with the Sites, user experience preferences, IP address, and other information that may help Spur improve the customer experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include, but is not limited to, the following:

Log Information

When You visit Spur’s Web sites We automatically collect and store certain information in Our server logs. This type of information includes details of how You interacted with Our Sites, Services, or applications. It may include information such as: IP address, Unique Device Identifier, or CallerID/ANI (Automatic Number Identification) information, content of Web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; application usage activity, hardware information, hardware and system settings, browser type, browser language, the date and time of Your request, referral URL, etc.

Automatic Collection

Spur and its partners use cookies or similar technologies to analyze trends, administer Spur’s Sites, track users’ movements around the Site, and to gather demographic information about Our user base as a whole.

Cookies

A cookie is a small, data file that is managed by Your Web browser or other application and stored on Your local system. Spur uses session and persistent cookies to, among other things, identify Your computer during a particular interaction and analyze Your behavior during a particular visit. Most Web browsers provide You with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If You choose to decline cookies, You may not be able to fully use Spur’s Sites, Services, or applications.

Pixel Tags

Pixel tags, also known as Web beacons, help Spur better manage user experience and content tracking. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by Spur or an affiliate organization. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but minimize distraction.

Third Party Data Sources

Spur may leverage external data sources in order to provide context and background on the users of its Sites, Services, or mobile applications in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

Do Not Track and Third Party Advertising Cookies

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify Web sites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most Web sites, including Spur Sites, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal. You can, however, make decisions about Your privacy and the advertisements You receive.

Some of the ads You receive on Sites are customized based on predictions about Your interests generated from Your visits to different Sites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising.

We partner with a third party to manage Our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide You advertising based upon Your browsing activities and interests. If You wish to opt out of interest-based advertising click here. Please note You will continue to receive generic ads.

As an alternative to the opt-out, You can also elect to block all cookies from first parties (such as Spur) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into Your browser software. Please note, however, that if You do decide to block cookies, some parts of Spur’s Sites may not function correctly.

Retention and Deletion of Personal Information

Spur will retain Your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and Your consent to such purposes(s) remains valid with respect to claims data and to file claims related to insurance coverage after termination of Spur’s relationship with You. When personal information is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual.

Use of Personal Information

In addition to any of the previously mentioned uses of personal information, Spur may use Your information collected on the Sites for such purposes as: (a) helping to establish and verify Your identity; (b) activating and maintaining Your account; (c) contacting You to offer Service updates and notices, promotional notices and other information about Services or other services available from Spur or its affiliates; (d) providing You with Services You have requested or authorized; (e) responding to Your questions, inquiries, comments and instructions; (f) improving the Sites by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, Service development and content improvement; (g) taking good faith steps to enforce terms and conditions; and (h) maintaining the security and integrity of the Sites and Spur’s systems.

Sharing and Disclosure of Personal Information

Primarily, We may share or disclose Your personal information in the following instances:

• To fulfill a service to You. For example, if You e-mail Us a question, We may use Your e-mail address to process Your request and respond to Your question.
• To provide the Services to You. We will disclose Your contact information as necessary to Workers that You request for Jobs so they may contact You to provide the Services. As set forth in a separate written agreement between You and Us.
• To offer You products from Our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that We believe may be of interest to You, or to assist such parties for research, administrative, and/or business purposes. These parties are obligated by contract to only use the information they are provided for the purposes specified by Spur.
• To unaffiliated third-party service providers, agents, or independent contractors who help Us maintain Our services and provide Us with other administrative services (including, but not limited to, providing Spur with insurance, order processing and fulfillment, providing customer service, maintaining and analyzing data, and sending customer communications on Our behalf). Spur requires these service-related companies to contractually comply with the principles set out in the Privacy Policy, and require them to use such information only for the purposes for which it was provided to them.
• To complete Your purchase of the Services. If You choose to make a purchase of one of Our Services, We may ask You for Your credit card number, billing address, and other information in connection with completing such purchase, and We may use such information to fulfill Your purchase. We may also provide such information, or other personal information provided by You, to unaffiliated third-parties to complete Your purchase (for example, to process Your credit card). These third-parties are contractually bound to use the information provided only for the purposes specified by Spur.
• To pay You. If You become a user of Spur, We may ask You for Your bank account and other necessary information to transmit Your earnings to You. We may also provide such information, or other personal information provided by You, to unaffiliated third-parties to complete Our payment to You. These third-parties are contractually bound to use the information provided only for the purposes specified by Spur.
• To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on Us, and to protect and defend Our rights or property, including Our rights and property and Our services, or act in urgent circumstances to protect the personal safety of You and Our other visitors.
• We may use anonymized or general information derived from the data We collect from You and aggregate it with information from Our other customers and visitors (“Non-Identifiable Aggregated Data”) for Our business purposes, including without limitation for analyzing customer needs and improving Our Services, and We will own all right, title and interest in any such Non-Identifiable Aggregated Data. Your data may be co-owned by third parties unaffiliated with Us.
• To protect against fraud and potential fraud. We may verify the information You provide to obtain Our Services through third parties who are contractually prohibited from using any information We provide to them for any purpose not specified by Spur. In the course of such verification, We may receive additional personal information about You from such services. In particular, if You use a credit card or debit card to purchase services with Us, We may use card authorization and fraud screening services to verify that Your card information and address match the information You supplied to Us, and that the card has not been reported as lost or stolen.
• To market Our Sites, Services, and mobile applications. We may use the information You provide in Your profile, such as Your name, picture, the date You created Your account, Your employment and/or education history, previous Jobs You have completed or submitted, ratings of other users, and self-description in Our marketing materials to third parties.

Legal Disclosure

We may disclose information about You and Your use of the services if We believe that such disclosure is reasonably necessary to: (i) comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding); (ii) protect or defend Our rights and/or property or the rights and property of others; (iii) enforce Our General Terms of Use and/or this Privacy Policy; (iv) respond to claims that the content(s) of a communication violates the rights of another; and (v) to meet Our legal and regulatory obligations, including, without limitation, as an employer and for tax purposes.

Also, circumstances may arise where, for business reasons, We may decide to reorganize, or divest all or part of Our business through sale, assignment, merger, acquisition, bankruptcy proceedings, or We may acquire a new business. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

People Under the Age of 18

The Services provided by Spur are not directed or available to persons under eighteen (18) years of age or the legal age of majority in Your state. If You become aware that Your child, who is under eighteen (18) years of age or the age of majority as may otherwise be dictated in Your state, is accessing the Services and providing personal information without Your consent, please contact Us by using the information provided in the Contact and Electronic Communication section of this Privacy Policy. Spur will take steps to remove the child’s personal information from Spur’s data collection systems and terminate Your child’s account should Spur determine that anyone under the age of majority as set in Your state or jurisdiction has accessed the Services.

Security of Information

Information submitted via the Internet, including through a Web page, mobile application, or e-mail is subject to interception or incorrect routing, and the Internet is not a fully secure communications channel. Please consider this prior to submitting any information to Spur via the Sites or a mobile application. While Spur follows generally accepted industry standards to protect the information submitted to Us, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while Spur strives to use commercially acceptable means to protect Your personal information, Spur cannot guarantee its absolute security. For information specific to credit card processing and data security please review these specific sections under this Privacy Policy.

Credit Card Processing and Data Security

Spur does not receive or distribute funds directly from or to You when You utilize the Sites or the Services. Spur utilizes a third party billing and payment processing gateway, provided by Stripe, Inc., who provides the infrastructure and security necessary to provide secure transmission of Your credit card transaction data. Stripe, Inc.’s terms of service are available at https://stripe.com/us/legal and its privacy policy is available at https://stripe.com/us/privacy, which are incorporated by reference herein. Spur can only accept credit cards for processing through Our secured payment processing gateway. Although We do not control the security environment for them and cannot make any guarantees regarding the secure processing of Your credit card transaction data, We want to inform You that Our credit card processor is compliant with the Payment Card Industry Data Security Standard (“PCI DSS”) as a Level 1 service provider. We demand that Our credit card processors are compliant with PCI DSS. PCI DSS is the bankcard industry’s stringent security standard. Examples of Our credit card processor’s security measures include: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of strong encryption for transmissions of order information to and from Our customers; restricting access to personal information; and periodic security audits by third party security experts.

Social Media

Any information, communications, or material of any type or nature that You submit to the Sites or through Spur’s Services (including, but not limited to any Spur Sites contained on a social media platform or Web site such as Facebook, Instagram or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at Your own risk and without any expectation of privacy. Spur cannot control the actions of other users of any social media platform or Web site and Spur is therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any Spur Site that is contained on a social media platform or Web site, You are representing and warranting to Spur that You have reviewed the applicable Privacy Policy and terms of use of such platform or Web site and that You will abide by all such provisions contained therein. Additionally, in the event that Spur offers a message board or any other interactive or social-type feature on the Sites, please be aware that these areas may allow You to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, tips, etc.). Although Spur may take certain precautions to protect those who use these areas of the Sites, Spur encourages You to be wary of providing any of Your personal information in such public forums. The information You submit can be collected and used by people You don’t know. Spur does not guarantee the privacy and safety of these areas and is therefore not responsible for any information You choose to submit. Your use of these features is fully at Your own risk.

International Users

If You are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that You are transferring information about You, including personal information, to a country and jurisdiction that does not have the same data protection laws as the European Union, and You consent to the transfer of information about You, including Your personal information, to the U.S.; and the use and disclosure of information about You, including Your personal information, as described in this Privacy Policy.

Monitoring and Enforcement

Spur has implemented various measures to monitor compliance with and enforce the elements in this Privacy Policy. If You have a privacy related inquiry, complaint or dispute, please contact Us at the postal or e-mail listed in the Contact and Electronic Communication section of this Privacy Policy.