Privacy Policy

Effective Date: September 6, 2024

Protecting your privacy is fundamental to the way RCAM Technologies Inc., doing business as Sperra (“Sperra”, “we”, “us”, or “our”), conducts business. This Privacy Policy explains how we may collect, use, and disclose your personal information when you access and use our online products and services that link to this Privacy Policy (including, our website, www.sperra.com), (the “Site”), our marketing activities, and other activities described in this Privacy Policy) (collectively, the “Online Services”). This Privacy Policy does not apply to your use of third-party sites linked to this website.

This Privacy Policy may change from time to time. We will make note of the changes on the Site and your continued access to the Online Services is deemed to be your acceptance of those changes, so we encourage you to check back periodically for updates.

You can jump to particular topics by going to the headings below:

What is Personal Information?
Personal Information Collected from You
How We Use Personal Information
Disclosure of Personal Information
Your Choices
Information Security
How We Retain Your Personal Information
Other Important Information
Children’s Policy
Changes to Our Privacy Policy
Contact Information
Supplemental California Privacy Rights Notice

What is Personal Information?

he term “personal information” in this Privacy Policy refers to any information or data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular identifiable natural person or household, or any other information or data that constitutes “personal information”, “personal data,” or “personally identifiable information.”

An identifiable natural person, or “Data Subject,” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Personal Information Collected From You

We collect the following information in the course of providing you these services:

Context	Types of Information	Primary Purpose for Collection and Use of Information
Client Information	We collect the names and contact data of our clients and their employees with whom we may interact.	We are executing on a contractual obligation in contacting our clients and communicating with them concerning normal business administration such as billing, registration, and our services.
Employment	If you apply for a job posting or become an employee of Sperra, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number or Personal Public Service Number. Providing this information is required for employment.	We use information about current employees to fulfil our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We are executing on a contractual obligation in using your information to have efficient staffing and workforce operations.
Cookies and First-Party Tracking	We use cookies on our website. “Cookies” are small pieces of data that a website sends to a computer’s hard drive while a website is viewed.	We have a legitimate interest in making our website operate efficiently and improving our marketing efforts and Online Services.
Cookies and Third-Party Tracking	We participate in the gathering of analytics using third-party cookies. This means that a third- party uses technology (e.g., a cookie) to collect data about your use of our website so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites.	We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics in improving our marketing efforts. Additionally, you can manage your cookie consent preferences in the cookie consent manager via our website’s cookie banner.
Email Interconnectivity	If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within.	We have a legitimate interest in understanding how you interact with our communications to you.
Feedback and Support	We collect personal information from you contained in any inquiry you submit to us regarding the Online Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue.	We have a legitimate interest in receiving and acting upon, your feedback, issues, or inquiries.
Order Placement	We collect your name, billing address, e-mail address, and phone number to process orders. We also use a third-party PCI compliant service to process your payment card number when you place an international order. Specifically, we use Wise for international payment processing.	We use your data to perform our contract to provide you with Online Services. For questions about how Wise processes your data, please refer to their Privacy Policy: https://wise.com/gb/legal/global-privacy-policy-en.
Payment Information	We collect payment and billing information when you pay for our Services. For example, we ask you to designate a billing representative, including name and contact information. You might also provide payment information, such as payment card details, which we collect via secure payment processing methods.	We are executing on a contractual obligation in obtaining payments for certain Online Services.
Website Interactions	We use technology to monitor how you interact with our Online Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our Online Services to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Social Media	When an individual interacts with our Services through social media networks, such as when someone follows us or shares our content on LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The information we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties.	We use this information to update and maintain the page to provide you with content and features of our Services, as well as to improve our product outreach. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We have a legitimate interest and/or may obtain your consent to collect this information.
Web Logs, Device and Usage Information	We collect information, including your device and browser type, operating system, operating system and browser version, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), derived IP address location, domain name, click-activity, referring website, and/or a date/time stamp for visitors. Additionally, we collect user account activity to include when an activity is completed, the type of activity taken, and the related data for the activity (for example, if a user sends a message, etc.).	We have a legitimate interest in monitoring our networks and visitors to our Online Services. Among other things, it helps us to monitor performance and to understand which of our Online Services and features are the most popular.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

Sperra has committed to complying with laws applicable to individual privacy and privacy breach notification that are enacted in the various jurisdictions in which it operates and offers its Online Services. Collectively referred to as “Data Protection Laws.”

If you are located in one of the United States with legislation protecting individual privacy, please also see the Your Choices below.

How We Use Personal Information

We use the personal information which you provide to us to perform our Online Services as outlined in this Privacy Policy. When you are our prospective or current business client or use our Site, we use personal information about you and your employees to:

deliver the Site;
carry out “Know Your Client” checks and screenings prior to starting a new engagement;
carry out client communications, services, billing, and administration;
configure our Online Services and your dashboard access, and other professional services that you may request;
secure client feedback;
deal with client complaints and requests;
create marketing materials such as white papers, case studies, and social media content; or
contacting and marketing to our clients.

We also process personal information about our clients/prospective clients and employees of our clients/prospective clients to:

contact our prospects and clients in relation to current, future, and proposed engagements;
send our prospects and clients newsletters, know-how, promotional material, and other marketing communications; or
invite our prospects and clients to events (and arrange and administer those events).

When you are a visitor to our Site or request marketing information, we may use your personal information to:

monitor the performance of our Site and analyze trends, usage, and activities in connection with our Site;
deliver targeted advertising where permitted by applicable law; or
respond to your requests, deliver information (including marketing information) to you based on your needs and interest.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent, unless there is an exception which applies under applicable law, such as those listed in the section below. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.

Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information we collect from you: (1) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others (2) to our authorized service providers such as our contractors and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; or (8) with your consent. We do not sell your personal information or otherwise share personal information with third parties for direct marketing purposes.

Your Choices

You can make the following choices regarding your personal information:

Right to Access Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
Right to Data Portability. You may have the right to obtain a copy of the personal information that you previously provided. We will provide this information in a portable format, to the extent technically feasible, readily usable format that allows you to transmit your personal information to another controller without hindrance, where the processing is carried out by automated means. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. Please refer to the Supplemental California Privacy Rights Notice for additional information.
Right to make Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
Right to Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Right to Object to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can
stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
Revocation Of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires
us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below

Please address written requests and questions about your rights to info@sperra.com.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:

A completed notarized statement executed by you and the consumer indicating that you have the authorization to act on the consumer’s behalf.

Information Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. For more information about our security practices and certifications, please visit our Trust Center which is available at trust.sperra.com.

The use of, and access to, your personal information by us is restricted to only authorized individuals who need to know that information to provide services to you, and who have received training about the importance of protecting personal information. Our service providers and business partners are also contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purposes. Unfortunately, no method of transmission of information via the internet or electronic storage is completely secure.

Although we take reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How We Retain Your Personal Information

Typically, personal information collected by Sperra will be kept for as long as the user’s account remains active or until the user deletes the information. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. 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 and/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.

Sperra may also anonymize your personal information (so that it can no longer be associated with you) for research, statistical or other business purposes. We may use this aggregated, anonymized, or de-personalized data indefinitely. We may retain personal information for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. You can request further details of retention periods for different aspects of your personal information by contacting us at info@sperra.com.

Other Important Information

Third-Party Providers. Some applications and services may be embedded within our Site or linked from our Site. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our Site or navigate away from our Site. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Policy does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.
Non-Personal Information.This Privacy Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.
If you have a disability and require an alternative format to this Privacy Policy, please email us at: info@sperra.com so that we may provide you with a more suitable format.

Children's Policy

Because we care about the safety and privacy of children online, our Site and its services are not intended for use of any kind by children under the age of 18. Additionally, we do not knowingly contact or collect personal information from children under 18. For more information on how to protect children’s privacy online, please visit https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

Changes to Our Privacy Policy

We will post any changes we make to this Privacy Notice on our website. If we make material changes to how we treat personal information we collect from you, we may notify you by email or through a notice on our website homepage, but any changes are effective when posted online and are deemed accepted by you when you continue to use or access the Site or the Online Services. The date this Privacy Policy was last revised is identified above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy on our website to check for any changes.

Contact Information

If you have questions or comments about this Privacy Policy, please email us at info@sperra.com or contact us by mail by providing a written request to Sperra at 2451 Signal St., San Pedro, CA 90731.