Effective date: July 17, 2019
Palmas Development Corporation (the “Corporation”) (DBA “SpendMap“) (“us”, “we”, or “our”) operates the www.spendmap.com website, the Free-Procurement Project Blog (free-procurement.com), the SpendMap support site (nae.spendmap.net/Free/Freesupport), and other related websites (collectively the “Sites”), and the SpendMap software and all related materials (collectively, the “Software“) .
This Privacy Policy (“Policy”) informs you of our policies regarding the collection, use and disclosure of personal data when you use our Services, as defined below, and the choices you have associated with that data.
We use your data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this Policy.
Definitions
Sites
Sites include the spendmap.com, free-procurement.com, spendmap.net and other websites operated by the Corporation
Software
Software is the SpendMap software and all related materials
Services
Our Services are the use of our Software and/or our Sites
Personal Data
Personal Data, or Personal Information, means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Services or from the Sites’ infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Services and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Sites or Software.
Types of Data Collected
Personal Data
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (Personal Data). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City, and Country
- Credit Card and billing information
- Cookies and Usage Data
Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered Personal Data. We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
Usage Data
We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Site.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
The Corporation uses the collected data for various purposes:
- To provide, maintain, administrate, and perform capacity planning of our Services
- To notify you about changes to our Services
- To allow you to participate in interactive features of our Services when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can develop new and enhance existing services and product offerings
- To monitor the usage of our Services
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), the Corporation’s legal basis for collecting and using the personal information described in this Policy depends on the Personal Data we collect and the specific context in which we collect it.
The Corporation may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
The Corporation will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
The Corporation will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.
The Corporation will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If the Corporation is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Policy.
Disclosure for Law Enforcement
Under certain circumstances, the Corporation may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
The Corporation may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of the Corporation
- To prevent or investigate possible wrongdoing in connection with the Services
- To protect the personal safety of users of the Services or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The Corporation aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where the Corporation relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
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 in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate the use of our Services (“Service Providers”), host the Sites or provide the Software on our behalf, perform Sites or Software related services or assist us in analyzing how our Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Site.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Links to Other Sites
Our Sites may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Services are not directed to anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Policy
We may update our Policy from time to time. We will notify you of any changes by posting the new Policy on this page.
You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. By continuing to use of the Services, you agree to the terms of any updates to this Policy.
Contact Us
The Corporation is accountable for all Personal Information in its control. The Privacy Manager to whom complaints or inquiries can be forwarded is as follows:
Darin Portnoff
Vice President Sales and Marketing
For Privacy concerns, complaints or inquiries, please email info@spendmap.com with the subject “Privacy Concern”