SPRINGHARE PRIVACY POLICY
Springhare Ltd (together with its affiliate companies – “Springhare”, “we”, “our” or “us”) respects your privacy and is committed to transparent privacy practices. This “Privacy Notice”, together with our "Cookie Policy" describes how we collect, use, store and share the personal data provided to us or otherwise collected by us.
If you are our customer, user, visitor or prospect (“you”), please read this Privacy Notice carefully and make sure that you fully understand and agree to it.
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services. If you are a user of the Platform on behalf of any of our customers, we suggest that you contact your account administrator with any questions.
1. Data Collection & Processing
1.1. Customer Data
Customer Data is data relating to identifiable individuals (“Personal Data”), which we analyze, process and manage on our customers’ behalf, as part of the Springhare Conversation Intelligence platform (“Services”). Specifically, this is data which is contained in call and video recordings, transcripts, e-mails, text messages and other communications and content, as well as data submitted by our Customers (including by connecting their systems with the Services);
Our Services enable Springhare Customers to record, transcribe, analyze and share the contents of their business communications, including phone calls, video conferences, emails and text messages, as well as their CRM and customer contacts (collectively, “Customer Data”).
Customer Data typically contains data which relates to identifiable individuals, such as the customer’s sales representatives, prospects, and other parties either taking part in their communications or mentioned there.
Certain privacy and data protection laws require that call recordings may only be initialized pursuant to one or more of the parties’ consent (whether explicit or implicit, depending on applicable law), or subject to certain restrictions. Accordingly, whilst Springhare supports these laws by providing our customers with features and options for how they use our Services – our customer is solely responsible for determining whether and how they wish to use our Services and such features, and to ensure that all individuals using Springhare on their behalf or at their request have given their informed consent to these practices, and that all legal requirements applicable to the collection, recording and use of data through our Services are fully met by them, including specifically in the context of an employment relationship.
Springhare processes Customer Data, and the personal data contained in it, strictly on our customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer.
Accordingly, to the extent that the EU’s General Data Protection Regulation (GDPR), UK’s General Data Protection Act, UK Data Protection Act (UKDPA) or any similar laws apply, our Customers will be deemed the ‘Data Controllers’ (under the GDPR, UK GDPR, UKDPA and similar laws) which controls such Customer Data; and Springhare will be deemed the ‘Data Processor’ or ‘service provider’ when processing such data.
1.2. User Data
User Data is account, contact and activity data relating to individuals who use the Springhare platform, mobile application, and other tools and features provided by us as part of the Services (collectively – “Platform”);
We collect and generate the following types of personal data concerning users of our Platform:
- profile information like your name, position, company, team, telephone numbers, email address, photo;
- account information such as email address and access tokens;
- usage and analytical information including connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies installed or utilized on their device;
- content you provide through communicating with us, for example audio and/or video conversations for support and training purposes; and your responses to questionnaires, surveys, or requests for feedback.
Whilst Springhare processes such User Data on its customers’ behalf (where it is included in Customer Data), we also use it for our own purposes, as described in Section 3 below. Accordingly, to the extent applicable – our customer will be deemed the ‘Data Controller’ or ‘business’ with respect to such data; Springhare will also be deemed an independent and separate ‘Data Controller’ or ‘business’ with respect to such data; and with respect to those portions or copies of User Data that we process on behalf of our customer – we will also be deemed a ‘Data Processor’ or ‘service provider’.
1.3 Website, CRM & Prospect Data
Website, CRM & Prospect Data is data relating to our customers, visitors of our website (www.springhare.com), participants at our events, and any other prospective customer or partner who visits or otherwise interacts with any of our websites, online ads and content, emails or communications under our control (“Sites”).
We collect and generate the following types of personal data concerning our website visitors, customers and prospects:
- website usage information including connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;customer account information such as contact, contractual and billing details concerning our
- customers, which may also contain the details of their internal focal persons who directly engage with Springhare concerning their organizational account, e.g. the account administrators, billing contacts and authorized signatories on behalf of the customer; as well as the customer’s needs and preferences, as identified to us or recognized through our engagement with them);
- information concerning our customers and prospects for example contact and business details, our communications with such customers and prospects (correspondences, call and video recordings, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement).
We collect such data either automatically, through the data subject’s interaction with us or with our website, Platform or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
2. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
2.1. Customer Data
Springhare is the “Data Processor” of Customer Data, which we process on behalf of our Customers (who are the “Data Controllers” of such data). Our Service Providers who process such Customer Data on our behalf are the “sub-Processors” of such Customer data.
Accordingly, Springhare processes Customer Data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer. The Customer, as Controller of such data, will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Requests concerning the data they control).
For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to their Account Users and Customers whose data may be contained in Customer Data – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
2.2. User Data
Springhare is both a “Data Controller” and “Data Processor” of User Data. Such data is processed by Springhare for its own purposes (as described in Section 3 below), as an independent ‘Controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘Processor’.
2.3. Website, CRM & Prospect Data
With respect to such data, we assume the responsibilities of "Data Controller" (solely to the extent applicable under law), as set forth in this Privacy Notice. In such instances, our Service Providers processing such data will assume the role of “Data Processor”.
3. Our Legal Basis for Processing
3.1. Customer Data
Springhare processes Customer Data, and the personal data contained in it, strictly on our Customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer.
3.2. User Data and Website, CRM & Prospect Data
We use other types of Personal Data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Visitors, Prospects, Ourselves and our Services.
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of Personal Data as described herein (in general, or specifically with respect to the types of Personal Data you expect or elect to process or have processed by or via the Services, e.g. ‘special categories’ under the GDPR), your acceptance of our Terms and Conditions and acknowledgement that you have read and understood this Privacy Notice will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Notice. If you wish to revoke such consent, please contact us at support@springhare.com.
Specifically, we use this type of Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To train our Customers and user-facing Staff;
- To authenticate the identity of our Users, and to allow them access to our Services;
- To provide our Customers and Users with assistance and support;
- To gain a better understanding on how individuals use and interact with our Sites and Services, and how we could improve theirs and other users’ experiences, and continue improving our products, offerings and the overall performance of our Services;
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our Business Partners;
- To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 7 below);
- To facilitate, sponsor and offer certain events, contests and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our Business Partners may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations.
4. Data Retention
4.1. Customer Data
We retain Customer Data strictly on our Customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer.
4.2. User Data and Website, CRM & Prospect Data
We will only retain your personal information for no longer than is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
5. Data Residency
We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States of America and Ireland and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law; provided that Customer Data may only be processed in such locations as permitted in our Data Processing Addendum and other Commercial Agreements with such Customer.
While privacy laws may vary between jurisdictions, Springhare and its affiliates and Service Providers are each committed to protecting Personal Data in accordance with this Privacy Notice and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. Among others, we have ensured that all transfers of Personal Data which originate from the EEA and made at our direction or control are based on appropriate data transfer mechanisms as established under the GDPR.
6. Data Sharing
6.1. The below sets out our business or commercial purpose for sharing your data and the Categories of third-parties/recipients we share your data with:
Business or commercial purpose for sharing your data
- To send you marketing communications (where requested)
- To analyze the effectiveness of our marketing materials;
- To contact you;
- To fulfill your requests;
- To provide our services to you;To store our emails and data;
- To store our documents;
Categories of third-parties/recipients
- Marketing Information: To send you marketing communications (where requested)
Third-Party Data Processors, who provide/facilitate the following services:
- Hosting and server co-location services;
- Communications and content delivery networks (CDNs);
- Speech-to-text services;
- Data and cyber security services;
- Billing and payment processing services;
- Fraud detection and prevention services;
- Web analytics, e-mail distribution and monitoring services;
- Session or activity recording services;
- Remote access services;
- Performance measurement;
- Data optimization and marketing services;
- Social and advertising networks;
- Content providers;
- E-mails;
- Voicemails;
- Support and Customer Relation Management
6.1. Service Providers
We engage selected Third-Party Companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), speech-to-text services, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and Customer Relation Management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“).
Our Service Providers shall each be deemed as a ‘Data Processor’ or ‘service provider’ in circumstances where Springhare assumes the role of ‘Data Controller’; and where Springhare acts as the ‘Data Processor’ or ‘service provider’ for our Customer, the Service Provider shall be deemed as our ‘sub-Processor’ or ‘service provider’ (as further described in Section 2 above).
Accordingly, these Service Providers may have access to User Data and Website, CRM & Prospect Data; and if we have expressly listed them in our Sub-Processor List, they may also have access to Customer Data — all depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our Agreements with them. Please note, Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.
6.2. Third Party Websites and Services
Our Sites and Platform may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Notice. We encourage you to carefully read the terms and privacy policies of such website and third-party services. Springhare’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
6.3. Subsidiaries and Affiliated Companies
We may share Personal Data internally within our group, for the purposes described in this Privacy Notice. In addition, should Springhare or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, Personal Data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your Customer Data or Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
6.4. Customers and Other Users
Customer Data is typically shared and is available to the users belonging to such Customer’s Account. User Data is shared with the administrator(s) of the Customer’s Account to which such user belongs (including data and communications concerning such user’s account). In such cases, sharing such data means that the administrator(s) or other users of the same account may access it on behalf of the Customer, and will be able to monitor, process and analyze the Personal Data contained therein. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer).
Please note that Springhare is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the ‘Data Controller’ of such data (as further described in Section 2 above).
7. Data Disclosures
7.1. For Legal Compliance Purposes
In exceptional circumstances, and except as stipulated otherwise in our Data Processing Addendum and other Commercial Agreements with you, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a Subpoena, Search Warrant or Court Order (or similar requirement), or in compliance with Applicable Laws and Regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
8. Cookies
We and our Service Providers use cookies, pixels, and other technologies to enhance and improve our services, track site performance, perform analytics, and gain insights into service usage and activity performance, as well as for personalization purposes.
Cookies are small data packets sent to your web browser, which then sends them back to the server each time it accesses the site. Some cookies are deleted when you close your browser session, known as "Session Cookies." Others last for longer periods and are called "Persistent Cookies." We use both types.
"Persistent Cookies" help us remember your login details, making it easier for you to log in the next time you access the platform. We may also use these cookies and session cookies for additional purposes, such as facilitating the use of service features and tools.
Certain cookies are essential for our services to function properly and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, used for functional, performance, analytics, and marketing purposes, are optional. These include Google Analytics, which helps us understand user behavior on our services by tracking page content, clicks, movements, scrolls, and keystroke activities. You can find more information about Google Analytics' privacy practices at: https://www.google.com/policies/privacy/partners/. To opt out visit: https://tools.google.com/dlpage/gaoptout.
You can opt-in or opt-out of the use of optional cookies through the "Cookie Declaration" feature on our website. Opting out of certain cookies typically generates a new cookie that preserves your choice and informs our services during future visits so that the opted-out cookies are not utilized. You can also manage your cookie preferences and accept, remove, or entirely block cookies through your browser settings.
Please note that if you get a new device, install a new browser, or erase or otherwise alter your browser's cookie file (including upgrading certain browsers), you may clear the opt-out cookies installed once you opt-out. Therefore, you may need to opt-out again to prevent additional tracking.
9. Security
We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure Service Providers that process personal data on our behalf also have appropriate security controls in place.
Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse will never occur.
To protect the confidentiality of your account and protect from unauthorized use of your account, we recommend enabling two-factor authentication for all of your external accounts used to sign-in to our Sites, Platform or Services.
10. Your Privacy Rights & Additional Disclosures
10.1. European Residents (GDPR)
If you are resident in Europe (or a country that has adopted GDPR into their local legislation, such as the UK), you will have certain rights and we are obliged to provide you with specific information about how we use your Data.
10.1.1. Privacy Rights
You have certain rights with respect to your Data. These are:
- Right to request access: you may ask to see the personal data we hold about you. This right always applies but there are some exemptions, which means you may not always receive all the information we process.
Right to rectification if you believe the information that we hold about you is inaccurate, you can ask us to correct it.
-Right to erasureou can ask us to delete the information we hold about you in certain circumstances.
-Right to restriction of processing: you can ask us to stop using your Data in a certain way and in certain circumstances.
-Right to objectan object to our use of your personal data if we are processing it on the basis of our legitimate interest.
- Right to data portability: You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. This only applies to information you have given us.
- Right to withdraw consent: where you have provided your consent to us processing your Data, you have the right to withdraw your consent at any time.
- Right to lodge a complaint: if you are resident in the EU, you may lodge a complaint with the Supervisory Authority in the EU Member State where you are resident or where you work. For further information on your rights, please see the website of the Supervisory Authority of your EU Member State.
10.2. No Sale of Personal Data
Springhare does not sell personal data to third parties. Where the definition of “sale” includes data sharing for monetary or other valuable considerations, We confirm that We do not engage in such activities. Any sharing of personal data is limited to purposes outlined in this Privacy Notice, such as providing our services, complying with legal obligations, or based on your explicit consent, where required. All data sharing is governed by stringent contractual or legal safeguards to ensure the security and integrity of your information.
11. Choice & Consent
In accordance with global data privacy regulations, including the GDPR, we respect your choices regarding the use and disclosure of your personal data. This means that we are committed to providing you with clear options and the ability to control how your personal information is handled. Our approach is designed to ensure that your data is used in ways that you have explicitly agreed to, and that you are fully informed about any potential uses or disclosures of your information.
12. How to Exercise Your Rights
12.1. Opt-In for Third-Party Disclosures and New Uses
We will obtain your affirmative express consent (opt-in) before disclosing your personal information to a Third Party or using your personal information for a purpose other than those for which it was originally collected or subsequently authorized by you.
You can provide your opt-in consent through our website settings or by contacting us directly at support@springhare.com If you do not provide your consent, your data will not be shared with third parties or used for new purposes.
12.2. Other Rights
If you wish to exercise any of your other rights as detailed under section 8 above, please contact us at support@springhare.com
12.3. Direct Marketing
If you wish to object to our use of your email address for direct marketing purposes, please click on the ‘unsubscribe’ link at the bottom of any of our marketing emails.
13. Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
13.1. Service Communications
We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Customer Account, may also send you notifications, messages and other updates regarding their or your use of the Services. Such notifications and messages may also be sent by them to their own Customers (for example, invites, recordings or meeting summaries created through our Services). You can typically control your communications and notifications settings from your Springhare User profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like billing notices).
13.2. Marketing Content and Promotions
When you consent to receiving marketing communications from Springhare, we may notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means made available by you to us (e.g. phone, mobile or e-mail), through the Services, Platform or Sites, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Springhare at any time by sending an e-mail to: support@springhare.com changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
14. Additional Notices
14.1. Amendments
We may change our Privacy Notice from time to time. If we make changes we’ll revise the “Effective” date at the bottom of this document, and we will make our best efforts to provide prior notice on our Sites, Platform and/or Services. After such notice period, all amendments shall be deemed accepted by you. We will comply with applicable law with respect to any changes we make to this document and seek your consent to any material changes if this is required by applicable law.
14.2. Children
Springhare does not knowingly acquire or receive Personal Data from children under 16, and do not wish to do so. If we later learn that any User of our Services is under the age of 16, we will take appropriate steps to remove that User’s information from our account database and will restrict that individual from future access to the Service.
14.3. Sensitive Personal Information
We do not collect or process Sensitive Personal Information of Users or Customers. If this changes, we will update our Privacy Notice accordingly and seek your consent before processing such information.
14.4. Disputes
We hope we can resolve any concerns regarding Personal Data held with us. You can raise your concern or dispute by emailing our Data Protection Officer at support@springhare.com
For those in the EEA or Switzerland, if you have a dispute with us relating to our data protection practices or are not satisfied with how we’ve addressed your concerns or questions, you may complain to an independent dispute resolution provider, at no cost to you. You also have the right to lodge a complaint with your local data protection authority.
14.5. Questions
If you have any comments or questions regarding our Privacy Notice please contact Springhare’s DPO at support@springhare.com
