This Privacy Policy is incorporated by reference into the Spontaneous Paid Opportunities Today Inc. End User License Agreement and Terms of Use (the “EULA”). The term “Spotwork,” “we,” and “us” includes Spontaneous Paid Opportunities Inc. and our affiliates and subsidiaries. The Privacy Policy explains how Spotwork may:

“Personal Information” means information about an identifiable individual, including any information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, date of birth, email address, social insurance number, mailing and/or physical address, government identification number(s), government identifications, your photograph, phone number and other information or data that identifies you. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to identify a specific individual.

THE SERVICE COLLECTS YOUR INFORMATION

We collect Personal Information when you:

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.

Personal Information Collection. If you are a Professional or Requester, then you must register to use the Service. To register, you may need to provide Personal Information. If you are a Professional, this Personal Information may include your name, address, phone number, and email address. Requester representatives will be asked to provide their name, their Company name, address, phone number, and email address. You may also provide other optional information. When you provide us with your Personal Information, you are providing us your implied consent to collect and use your Personal Information to fulfill the Service or requested information. You may withdraw your consent to our collection, use and disclosure of your Personal Information at any time upon reasonable notice to hello@spotwork.co.

Using the Service. We collect information you post through the Service. For example, if you are a Requester, we will collect the information you include when you post the desired skills, location, date, start time (as applicable), project length (as applicable), pay rate and any required certifications of a project. If you review or rate Professionals or Requesters, we will also collect the information incorporated into those reviews or ratings.

Making and Receiving Payments. If you are a Requester, when you make payments through the Service, you may need to provide Personal Information to our third-party service providers, such as your credit card number. If you are a Professional, then you may need to provide your banking information, your social insurance number, and your date of birth to our third-party service providers so that you can get paid.

Customer Support. We may collect Personal Information through your communications with our customer-support team.

Location Information from Your Mobile Device. For improved accuracy with payments, check ins and check outs, customer support, and safety, Spotwork may collect and store your location information if you enable your mobile device to send it to us. Collection of your location may improve the provision of the Service. The App uses location-based APIs as an essential part of its functionality, and certain features of the App will not function correctly if location services are disabled in the App.

Cookies, Automatic Data Collection, and Related Technologies. The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.

When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly.

By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.

HOW SPOTWORK USES YOUR INFORMATION

We use Personal Information to

We may use aggregate information for any purpose, including for marketing purposes.

To provide the Service your Personal Information is used for the creation and security of your account, to identify you as a user in our system, to provide administration of the Service, to send you an e-mail to verify ownership of the e-mail address provided by you when your account was created, to send you administrative e-mail notifications, to perform a background check, to send you alerts you have configured, and to send you promotional communications.

Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide and improve our services.

Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.

Marketing. We may use information to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.

Aggregate Data. We may anonymize and aggregate data collected through the Service and use it for any purpose.

SPOTWORK MAY DISCLOSE YOUR INFORMATION

We may share your information:

We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. These vendors and service providers can only use such information in the provision of their services to us, are required to maintain confidentiality and are required to return such information upon completion of their services. We may share your Personal Information with service providers that are authorized by us and perform services on our behalf, including background checks, payment processing, customer support, web hosting, information technology, fraud control, direct mail and email distribution, events, contest, sweepstakes and promotion administration, marketing, and analytics services. We may also share Personal Information that is aggregated or de-identified information with authorized third parties for legitimate business purposes. We may also use the information you provide to support research and innovation on topics of public interest and importance including providing work opportunities to individuals with criminal backgrounds.

Displaying to Other Users. If you are a Professional, we will share some of your Personal Information with Requesters when you apply for projects that Requesters have posted via the SPOTWORK website or mobile phone application so that they may evaluate you. We are not responsible for privacy practices of the other users who will view and use the posted information. All users of our Service are subject to this Privacy Policy and the EULA.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company 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. The use of your Personal Information following any of the foregoing events should be governed by the provisions of this Privacy Policy in effect at the time such Personal Information was collected.

We may also disclose your Personal Information with your permission.

SECURITY AND STORAGE 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. We do not accept liability for unintentional disclosure. Your information will be kept as long as is necessary to facilitate the Service or as required by law.

By using the Service 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 Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an e-mail to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at hello@spotwork.co.

CHILDREN’S PRIVACY

We do not knowingly collect information from children under 13 and we do not want it. We will take steps to delete it if we learn we have collected it.

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at hello@spotwork.co. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

INTERNATIONAL USERS OUTSIDE OF UNITED STATES AND CANADA

Although the Services are accessible over the Internet and therefore available worldwide, the Services are intended for residents of and business in the United States and Canada only. If you choose to access the Services from locations outside the United States and Canada, such conduct is at your own risk and subject to the laws of the United States and Canada, which may differ from privacy laws and regulations in your state or home country, and you are responsible for compliance with any local laws and regulations. Nothing in the Services should be interpreted as a promotion or solicitation for any service of any nature that is not authorized by the laws and regulations of the country where you are located. Personal Information collected through or from using the Services may be stored and processed in the United States, Canada, or any other country in which Spotwork or its subsidiaries, or agents maintain facilities, and by using the Services you consent to any such transfer of information outside of your country. Users from outside the United States and Canada should not use or access the Services or disclose any information, including Personal Information, through the Services. Individuals outside the United States and Canada who disclose any data through the Services, including Personal Information, hereby acknowledge and consent to such data being stored in the United States, Canada or any other country, and transferred outside your country.

By choosing to visit the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by laws of the Province of Ontario and the adjudication of any disputes arising in connection with Spotwork or the Service will be in accordance with the EULA.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Canada and the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an e-mail to hello@spotwork.co.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so review it periodically.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law. Your continued use of the Service following any such change means that you have consented to such new uses.

Contact Information

Spontaneous Paid Opportunities Today Inc.

33 Bloor Street East, 5th Floor

Toronto, Canada

M4W 3H1

hello@spotwork.co

Attn: Privacy Officer