Privacy Policy

Updated: Dec. 1, 2021

Squire Technologies, Inc. ("Squire", "we" or "us") takes data privacy seriously. This privacy policy (Privacy Policy) describes our practices and your rights in connection with Personal Information (defined below) that we collect, process, or share when you use (a) the Consumer User-facing Squire Flagship mobile application, (b) the Enterprise Customer-facing Commander mobile application, (c) any Consumer User-facing Squire-powered application (mobile, widget or otherwise) developed specifically for an Enterprise Customer (an "Enterprise Branded App"), (d) our websites, (e) and any other online product and/or services provided by Squire and through other interactions and communications you have with Squire (collectively, the "Squire Services").

This Privacy Policy applies to visitors to our website and any user of the Squire Services. When you access or use the Squire Services, you agree to the terms and conditions of this Privacy Policy and that the information contained in this Privacy Policy serves as notice at or before the point of collection for all Personal Information collected as described below.

In this Privacy Policy, we cover:

I. WHAT PERSONAL INFORMATION WE COLLECT

"Personal Information" is data that relates to you that can identify you as an individual, either on its own or in combination with other information. Personal Information does not include data that has been aggregated or de-identified such that you can no longer be identified using means reasonably available to us. The Personal Information we actually collect depends on the nature and type of Squire Services you use or interact with. The types of Personal Information we may collect will fall in the following general categories:

We may also receive information from other sources and combine that with information we collect through our Services. For example:

II. WHERE/HOW DO WE COLLECT PERSONAL INFORMATION

We collect Personal Information about you from:

III. HOW WE USE YOUR PERSONAL INFORMATION

IV. SHARING OF PERSONAL INFORMATION

In limited circumstances, we may share your Personal Information in order to provide and improve the Squire Services or as required by applicable law. Where required by applicable law, we will only share your Personal Information with third parties with your consent. We may share your Personal Information as follows:

V. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our website and use our Services, as well as when you visit other online sites and services. For more information about these technologies and service providers, please refer to our Cookies Policy.

VI. LEGAL BASES FOR PROCESSING

We process your Personal Information as follows:

VII. DATA PROTECTION RIGHTS

Squire values your rights with respect to your Personal Information. In accordance with applicable law, you may be entitled to some or all of the following:

VIII. HOW TO EXERCISE YOUR RIGHTS

Squire will comply with individual's requests, including access, correction, and/or deletion of the Personal Information it stores in accordance with applicable law.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.

You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request.

You may exercise the above rights by emailing us at privacy@getsquire.com.

In addition, if you are in the European Economic Area or the United Kingdom, you have the right to complain to a data protection authority about our collection and use of your Personal Information. The data protection authority for the UK is the Information Commission's Office - whose website is https://ico.org.uk. Contact information for data protection authorities based in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

IX. OTHER CHOICES YOU HAVE

Account Information

You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at privacy@getsquire.com. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated the policies governing the Squire Services, we may seek to resolve the issue before deleting your information.

Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Squire app wants permission to access certain types of data and will let you consent (or not consent) to that request.

Marketing Communications

At times, we or our Enterprise Customers via the Squire Services may send you marketing and promotional information about products and services that may be of interest to you. With respect to marketing communications, you have many choices regarding the use of your Personal Information, as described below:

FOR CALIFORNIA RESIDENTS - "Do Not Sell My Personal Information"

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time. We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out you (or your authorized representative) may submit a request to us by sending us an email at privacy@getsquire.com. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to Personal Information sales at any time by sending us an email. We will only use Personal Information provided in an opt-out request to review and comply with the request.

X. SOCIAL SHARING FEATURES

The Squire Services may integrate with social sharing features and other related tools which let you share actions you while using the Squire Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please note, we are not responsible for the privacy practices of those social sharing services. Please contact the relevant social sharing service for more information on how they handle your Personal Information and their privacy practices.

XI. CALIFORNIA SHINE THE LIGHT DISCLOSURE

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Squire does not share your Personal Information with third parties for direct marketing purposes unless you provide us with consent to do so.

XII. COOKIES

When you visit our websites or use our mobile applications provided as part of the Squire Services, we may collect information, including Personal Information, about you through the use of cookies, web beacons, pixels, and other similar tracking technologies (collectively, "Cookies"). Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows us or a third-party to recognize you in order to help us learn about your use of the Squire Services and make your next use or visit better. Please see our Cookies Policy so you can learn more about how we may use Cookies.

XIII. INTERNATIONAL TRANSFERS OF INFORMATION

Information about you will be transferred to, or accessed by, entities located around the world as described in this Privacy Policy. Some of these entities may be located in countries (such as the United States) that do not provide an equivalent level of protection for Personal Information as your home country.

We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.

XIV. SECURITY, RETENTION, AND STORAGE OF PERSONAL INFORMATION

We use commercially reasonable procedures to protect the information that we collect. However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Squire will keep your Personal Information for seven years. Once this time period has expired, we will delete your data.

XV. CHILDREN UNDER 16

The Squire Services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If we learn that we have collected any Personal Information from a child under the age of 16 without verifiable parental consent, we will delete that information from our database as quickly as possible. If you believe that we may have collected information from a child under 16, please contact us at privacy@getsquire.com.

XVI. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights with respect to your Personal Information as granted under applicable law. Unless permitted by applicable law, we will not:

XVII. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your Personal Information, or to this Privacy Policy, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

XXVIII. HOW TO CONTACT US

If you have any questions about this Privacy Policy or any information incorporated herein, please contact us at privacy@getsquire.com or write us at Squire Technologies, Inc., 139 Eldridge Street, New York, NY 10002.