Privacy policy

When you visit our website or use Spoke services, you trust us with information. We are committed to keeping that trust, and that starts with helping you to understand our privacy practices. 

Townsend Street Labs, Inc. (“Spoke”, “we”, or “our”) operates the website www.AskSpoke.com  (the “Site”) to provide information about our services (the “Services”), which include without limitation offering an innovative ticketing system and knowledge base that gets smarter with every interaction using artificial intelligence and unrivaled Slack integration via a license. We also provide Services via an interactive portion of the Site, as well as through external applications.

This privacy policy (“Privacy Policy”) informs you of our policies regarding the collection, use and disclosure of Personal Data (as defined) and other data when you use our Site or Services and the choices you have associated with that data.

We use your data to provide and improve the Site and Services and to collect information to market our Services. By using the Site or Services, you agree to the collection and use of information in accordance with this policy.

We collect several different types of information for various purposes to provide and improve our Site and Services to you.

Please note that we will never sell your personal information (name, address, email, etc.) to any third party.

I. Types of Data Collected

A.      Personal Data

While using our Site or Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This personally identifiable information may include, without limitation:

We may use your Personal Data to contact you with marketing or promotional materials, such as newsletters, 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 contacting us at marketing-unsubscribe@askspoke.com, following an unsubscribe link or instructions provided in any email we send.

B.       Usage Data

We may collect information on how the Site is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

C.      Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We may use this data to provide additional Site features or to improve and customize our Site. You can enable or disable location services when you use our Site at any time by way of your device settings.

D.       Tracking Cookies Data

We may use Cookies (a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive) and similar tracking technologies to track the activity on our Site, and these Cookies and technologies hold certain information. We may also use other tracking technologies such as beacons, tags, and scripts to collect and track information and to improve and analyze our Site and Services. 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 Site and Services.

Here are examples of Cookies we may use:

II. Data Use

Spoke may use the data it collects for various purposes:

III. Data Retention and Transfer

Spoke will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy 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.

Typically, we retain Personal Data about you for as long as you have an open user account with us and within twelve (12) months after you close your user account unless otherwise agreed upon in an executed agreement. Thereafter, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. Spoke maintains the capability to delete Personal Data within 30 days upon request.

Spoke 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 Site, or we are legally obligated to retain this data for longer periods.

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 the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Spoke will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Data 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.

IV. Data Disclosure

A. Business Transaction

If Spoke 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 Privacy Policy.

B. Disclosure for Law Enforcement

Under certain circumstances, Spoke 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).

C. Legal Requirements

Spoke may disclose your Personal Data in the good faith belief that such action is necessary to:

V. Data Security

The security of your data is important to us, but 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.

Spoke practices are that Personal Data transmitted over public networks is encrypted with the latest recommended secure cipher suites, including the use of TLS 1.2 protocols, and SHA2 signatures, which also applies to Personal Data transmitted between you and Spoke and through the Services.

Spokes uses industry standard methods for data encryption and key management to protect data at rest. Furthermore, we authorize select employees to access Personal Data only as needed to fulfill their job responsibilities. To learn more about our security practices, please visit our website at https://www.askspoke.com/security/

VI. Our Policy on “Do Not Track” Signals under the California Online Protection Act (“CalOPPA”)

We do not support Do Not Track (“DNT”). DNT 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 DNT by visiting the Preferences or Settings page of your web browser.

VII. Your Data Protection Rights under the GDPR

If you are a resident of the European Economic Area, you have certain data protection rights. Spoke 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 at privacy@askspoke.com

In certain circumstances, you have the following data protection rights:

The right to access, update, or delete Personal Data: Whenever 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 Personal Data rectified if that information is inaccurate or incomplete and you are unable to perform these actions yourself.

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 Data.

The right to data portability: You have the right to be provided with a copy of Personal Data 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 Spoke relied on your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain: Spoke is committed to resolving all inquiries or complaints about the collection or processing of your personal information. Individuals are encouraged to contact us with their concerns. If you feel your complaint is not resolved by contacting us, you should seek assistance from a Data Protection Authority about our collection and use of your Personal Data. For more information, please visit the European Commission’s web page to identify your local data protection authority in the European Economic Area: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.  Spoke may act as either a Data Processor or Data Controller (as defined by the GDPR). In general, Spoke will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of the Services to customers, in which cases we are the processor of Personal Data. If we are acting as the Data Processor of your Personal Data rather than the Data Controller, please contact the Data Controller first to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.  If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@askspoke.com.

VIII. Legal Basis for Processing Personal Data Under the 

GDPR

If you are from the European Economic Area (“EEA”), Spoke’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data (as defined by the GDPR) we collect and the specific context in which we collect it.

Spoke may process your Personal Data because:

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service or other contract with you, which enables us to provide you with the Services.  When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Consent:  In some cases, we may process Personal Data based on the consent you expressly grant to us at the time we collect such data.  When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.  

First and last name

Email address

Telephone number

IP address

Web browser information

Page view statistics

Browsing history

Usage information

Transaction information (e.g. transaction amount, date and time such transaction occurred)

Log data (e.g. access times, and software information)

Examples of these legitimate interests include:

Operation and improvement of our business, products and services

Marketing of our products and services

Provision of customer support

Protection from fraud or security threats

Compliance with legal obligations

IX. Site Providers

We may use third-party services (“Site Providers”) to monitor and analyze the use of our Site and Services and perform tasks on our behalf. These Site Providers have access to your Personal Data only to perform these tasks and are obligated not to disclose or use it for any other purpose. Here are some examples of Site Providers:

A. 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. These data are 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 Site 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 visit 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.

B. Google AdWords and Behavioral Remarketing Services

Google AdWords remarketing service is provided by Google Inc.

You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on—https://tools.google.com/dlpage/gaoptout—for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

Spoke may also use remarketing services to advertise on third-party websites to you after you visited our Site (via Google AdWords or other providers), and such remarketing vendors use cookies to inform, optimize, and serve ads based on your past visits to our Site.

X. Links to Other Sites

Our Site 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 Privacy 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.

XI. Children’s Privacy

Our Site is not intended for people under the age of 18 (each a “Child”).

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 at privacy@askspoke.com. If we become aware that we have collected Personal Data from a Child without verification of parental consent, we take steps to remove that information from our servers.

XII. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and by updating the “effective date” at the top of this Privacy Policy. Please review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted.

XIII. Contact Us

If you have any questions about this Privacy Policy, please contact us via email at privacy@askspoke.com.

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