Privacy Policy and Cookie Policy

Effective May 25, 2018
Last Revised: May 25, 2018

Background:

Azul Partners, Inc., understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. DEFINITIONS AND INTERPRETATIONIn this Policy the following terms shall have the following meanings:“Account”means an account required to access and/or use certain areas and features of Our Site;“Cookie”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;“Our Site”means this website, spendmatters.com; and“We/Us/Our”means Azul Partners, Inc., an incorporated company registered in the United States, whose registered address is 625 N. Michigan Ave., Suite 1220, Chicago, Illinois, 60611.
  2. INFORMATION ABOUT US
    1. Our Site, spendmatters.com, is owned and operated by Azul Partners, Inc., an incorporated company registered in the United States, whose registered address is 625 N. Michigan Ave., Suite 1220, Chicago, Illinois, 60611.
    2. We can be contacted at privacy@spendmatters.com
  3. SCOPE – WHAT DOES THIS POLICY COVER?
    This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
  4. WHAT DATA DO WE COLLECT?
    Some data will be collected automatically by Our Site. (For further details, please see section 12 on Our use of Cookies and Our Cookie Policy.) Other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:
    1. Name;
    2. business/company name;
    3. job title;
    4. profession;
    5. industry;
    6. contact information such as email addresses and telephone numbers;
    7. demographic information such as zip/postal code, preferences and interests;
    8. financial information such as credit / debit card numbers;
    9. IP address (automatically collected);
    10. web browser type and version (automatically collected);
    11. operating system (automatically collected);
    12. a list of URLs starting with a referring site, your activity on Our Site, and the site to which you exit (automatically collected)
  5. HOW DO WE USE YOUR DATA?
    1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
    2. We use your data to provide the best possible products and services to you. This includes:
      1. Providing and managing your Account;
      2. Providing and managing your access to Our Site;
      3. Personalizing and tailoring your experience on Our Site;
      4. Supplying Our products and services to you;
      5. Personalizing and tailoring Our products and services for you;
      6. Responding to communications from you;
      7. Supplying you with notifications, e.g. email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by following the instructions contained within the notification);
      8. Market research, in the form of conducting voluntary surveys;
      9. Analyzing your use of Our Site (and gathering feedback) to enable Us to continually improve Our Site and your user experience
    3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
    4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR.
    5. If you order products or services directly from Us, We will use the personal information you provide to process that order, and to provide the product or service or renew the subscription in the future. We do not share this information with outside parties except to the extent necessary to complete that order.
    6. We currently do not work with any advertisers who may engage in what is known as “behavioral advertising” (advertising which is tailored to your preferences, based on your activity). Any personal data derived from advertising on Our Site is not shared with or otherwise passed on to any third parties.
    7. We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:a) you have given consent to the processing of your personal data for one or more specific purposes;b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;c) processing is necessary for compliance with a legal obligation to which we are subject;d) processing is necessary to protect the vital interests of you or of another natural person;e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/orf) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Specific examples of legitimate business interests include: where the processing enables us to enhance, modify, personalize or otherwise improve products/services/ communications for the benefit of our customers; to identify and prevent fraud; to enhance the security of our network and information systems; to better understand how people interact with our websites; to determine the effectiveness of promotional campaigns and advertising.
  6. HOW AND WHERE DO WE STORE YOUR DATA?
    1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct a periodic review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy, found here.
    2. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
    3. Steps We take to secure and protect your data include:
      1. PCI compliance on all website and application hosting that process payments
      2. Encrypting your data in transit
      3. Keeping access to personal information restricted to employees, contractors and sub-processors in order for them to process it.
      4. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
  7. DO WE SHARE YOUR DATA?
    1. We may share your data with other companies/partners in Our group. This includes Our holding company and its subsidiaries.
    2. We may contract with third parties to supply products and services to you on Our behalf. These may include:payment processing,delivery of products and/or services,search engine facilities,advertising andmarketing.In some cases, the third parties may require access to some or all of your data. (We contract with PayPal for payment processing services. Note: all PayPal transactions are subject to the PayPal privacy policy.) Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).
    3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All data for statistics will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
      1. We may periodically conduct both business and individual customer surveys, per Section 5.2.8. Your personal data and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary. We may take the data We receive from individuals responding to our customer surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, employment, industry sector, or other demographic information). This aggregated, non-personally identifying information may be shared with third parties.
    4. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
  8. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
  9. HOW CAN YOU CONTROL YOUR DATA?
    1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details, and/or by managing your Account).
  10. YOUR RIGHT TO WITHHOLD INFORMATION AND YOUR RIGHT TO WITHDRAW INFORMATION AFTER YOU HAVE GIVEN IT
    1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    2. You may restrict your internet browser’s use of Cookies. For more information, see section 12.
    3. You may withdraw your consent for Us to use your personal data as set out in section 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
  11. HOW CAN YOU ACCESS YOUR DATA?
    You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at privacy@spendmatters.com, or using the contact details below in section 15.
  12. WHAT COOKIES DO WE USE AND WHAT FOR?
    1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
    2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. These Cookies are not integral to the functioning of Our Site.
    3. All Cookies used by and on Our Site are used in accordance with current US and EU Cookie Law.
    4. Before any Cookies are placed on your computer or device, we will request your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. Certain features of Our Site depend on Cookies to function. US and EU Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed in section 12.6 below, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
    5. Our Site uses analytics services through the use of cookies to measure traffic and provide other necessary metrics for the wellbeing of our site. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies; however, while Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
    6. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
    7. You can choose to delete Cookies at any time, however you may lose any information that enables you to access Our Site – including, but not limited to, login, session availability and personalization settings.
    8. It is recommended that you keep your internet browser and operating system up to date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
  13. YOUR RIGHTS UNDER GDPRUnder the GDPR, you have:
    1. the right to request access to, deletion of or correction of, your personal data held by Us;
    2. the right to complain to a supervisory authority;
    3. be informed of what data processing is taking place;
    4. the right to restrict processing;
    5. the right to data portability;
    6. object to processing of your personal data;
    7. rights with respect to automated decision-making and profiling (see section 14 below).
    To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.
  14. AUTOMATED DECISION-MAKING AND PROFILING
    1. In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
    2. The right described in section 14.1 does not apply in the following circumstances:a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;b) The decision is authorized by law; orc) You have given your explicit consent.
    3. Where We use your personal data for profiling purposes, the following shall apply:a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;b) Appropriate mathematical or statistical procedures will be used;c) Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; andd) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
  15. CONTACTING USIf you have any questions about Our Site or this Privacy Policy, please contact Us by email at privacy@spendmatters.com, by telephone at 773.525.7406, or by mail at the following address:
    Azul Partners, Inc.
    Attn: Privacy Policy Inquiry
    625 N. Michigan Ave, Suite 1220
    Chicago, IL 60611

    Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).
  16. CHANGES TO OUR PRIVACY POLICY
    We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.