1. Who We Are and What We Do

At Spot ERTC, we operate a web-based platform that saves companies money. This Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.

2. Scope

This Privacy Policy applies to Personal Information Processed by us in our business, including on our website (each a “Site”), applications, and other online offerings (collectively, the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.

3. Transparency/Notice

a) Personal Information We Collect and How We Use It. The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, or visitor (together, “Individuals”) and the requirements of applicable law.

‍Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us. Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

‍Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.

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b) How We Use Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested including to:

Manage Individual information and accounts; Respond to questions, comments, and other requests;Provide access to certain areas, functionalities, and features of our Services; Answer requests for customer or technical support; and

For Administrative Purposes including to:

Measure interest and engagement in our Site and Services; Conduct research and development; Improve our products and Services; Develop new products and Services; Ensure internal quality control; Verify Individual identity; Communicate with you about your account, activities on our Site and Services and policy changes; Process your financial information and other payment methods for products or Services purchased; Process applications and transactions; Prevent potentially prohibited or illegal activities; and Enforce our Terms.

To Market Our Products and Services. We may use Personal Information to provide you with materials about Services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include:

To notify you about products and services that may be of interest to you;To provide Services to you and our sponsors; and Other purposes you consent to or are disclosed when you provide Personal Information.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.

De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Other Uses. Spot ERTC may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

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c) Cookies, Pixel Tags/Web Beacons, and Analytics Information

We may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.

Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.

Analytics. We may also use third-party analytics services to collect information regarding user behavior on our Site and Services.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;

Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;

4. Onward Transfer—How We May Disclose Your Information

a) Information We Share

We may share your information as described in this Privacy Policy: We Use Service Providers. We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.

‍Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

‍Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

5. Your Choices: Right to Object to Processing

a) General

You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site or Services for other legal purposes as described above.

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b) Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

6. Rights of Access, Rectification, Erasure, and Restriction

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Spot ERTC, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will Process such requests in accordance with applicable laws. To protect your privacy, Spot ERTC will take steps to verify your identity before fulfilling your request.

7. Data Retention

Spot ERTC retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

9. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

10. Terms of Service

This Privacy Policy is incorporated by reference into the Spot ERTC Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “Spot ERTC,” “we,” and “us” include Spot ERTC and our affiliates and subsidiaries.

11. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

[email protected]

12. Definitions

“Personal Information” is any information relating to an identified or identifiable natural person.“Process” or Processing means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.