Privacy Policy

Spear Technologies, Inc., its subsidiaries and affinities (“Spear Technologies,” “we,” “us,” “our,”) is committed to maintaining the privacy and confidentiality of an individual’s personal information. We want to share our policy for collecting and handling your personal data and other important topics related to your privacy and data protection.

INTRODUCTION

Spear Technologies, Inc. is providing the following privacy policy (the “Privacy Policy”) to demonstrate our commitment to privacy. Spear Technologies may change this Privacy Policy periodically in order to address new issues or to consider changes on our website. Please refer back to this Privacy Policy regularly because your use of the Site signifies that you agree to the terms and conditions of this Privacy Policy, as amended from time to time.

Spear Technologies collects personally identifiable information (Personally identifiable information is any information that can be used to identify or contact a specific individual and any other information about that individual.) about you through:

  • Our websites and other software applications made available through computers and mobile devices (the “Sites”) and

Contact

If you have any questions about our privacy policy or our practices, please contact our privacy team via email at privacy@spear-tech.com or by Registered Mail Attn: Privacy Officer, 145 Corte Madera Town Ctr. #186 Corte Madera, CA 94925or by calling toll free at 1 (415) 429-2320

Questions regarding Information Security should be directed to Spear Technologies Information Security Officer by email at privacy@spear-tech.com

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

General identification and contact information

  • Your name, e-mail address, telephone numbers, gender, marital status, family status, date of birth, place of birth, educational background, physical attributes, activity records, driving records, photos and video images, employment history, skills and experience, professional licenses affiliations, relationship to policyholder, insured or claimant, date and cause of death, injury, or disability.
  • identification numbers issued by government bodies or agencies such as Social Security Number, passport number, tax identification number, military identification number, or drivers licenses or other license numbers.

Financial

  • Bank account numbers and account details, credit history and or credit score

Medical

  • In certain cases, we may receive information about your current or former physical or mental or medical condition, health status, injury or disability information, medical procedures performed, personal habits (for example, smoking or consumption of alcohol), prescription information and medical history.

Telephone recordings

  • Recordings of telephone calls to our staff
  • Information to investigate crime, including fraud and money laundering: For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.

Other

  • In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud
  • Location and identification of property insured (for example, property address, vehicle license plate or identification number);
  • Travel arrangements including reservation numbers, destination and hotel details
  • Policy details and claim numbers, details of policy coverage and cause of loss; and
  • Prior accident or loss history, your status as director or partner or other ownership or management interest in an organization and other insurance policies you hold

USE OF PERSONALLY IDENTIFIABLE INFORMATION

Spear Technologies will not sell or otherwise transfer or disclose personally identifiable information to third parties not affiliated with Spear Technologies without your prior consent (except as may be required by law, such as a court-ordered subpoena, search warrant, or other court order; or required by exigent circumstances). That means that Spear Technologies will never disclose your name, e-mail address, street address or phone number to third parties not affiliated with Spear Technologies without your consent.

Personally Identifiable Information usage:

  • Communicate with you and other interested parties to manage your claim.
  • Send you important information regarding your claim and other administrative information.
  • Make decisions about claim assessment, processing and settlement.
  • Manage claim disputes, where applicable.
  • Use during the normal course of pre-employment contracting during the recruitment process.
  • Manage our business operations to comply with internal policies and procedures, including those relating to auditing finance, accounting and billing, IT systems, data and website hosting, business continuity, document and print management.
  • Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
  • Use during the normal course of pre-employment contracting during the recruitment process.
  • Conduct satisfaction surveys.
  • Resolve complaints, and handle requests for data access or correction.
  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and comply with legal process and respond to requests from public and government authorities (including those outside your country of residence).
  • Tailor your experience at our Site, and to compile and display content and information that we think you might be interested in and to display content according to such preferences.

Cookie usage

Spear Technologies collects non-personal identification information through the use of “cookie” technology and/or Internet Protocol (“IP”) address tracking. Cookies are small text files a web site can use to recognize repeat users and facilitate the user’s ongoing access to and use of the site.

We use cookies in the following manor

  • To maintain sessions across web requests.
  • Google Analytics cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Spear Technologies cannot control the use of cookies by advertisers or third parties displaying data on the Site or on the sites you visit using links from the Site. Most browsers are set to accept cookies. You can set yours to refuse cookies, or to alert you when cookies are being sent.

HOW WE SHARE YOUR DATA

Spear Technologies may make personal data available to the following parties for the purposes of claim assessment and processing or as per required by law:

Other insurance parties

  • In the course of processing claims, we may make Personal Data available to third parties such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms and other business partners.

Service providers

  • External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers.
  • IT systems, support and hosting service providers, document and records management providers and outsourced service providers that assist us in carrying out business activities.
  • Banks and financial institutions that service our accounts, third-party claim administrators, claim investigators, construction consultants, engineers, examiners, jury consultants, translators and similar third-party vendors.

Authorities and 3rd parties involved in legal action

  • We may share personal data with government or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate:
  • to comply with applicable law and regulations, including those outside your country of residence;
  • to comply with legal process;
  • to respond to requests from public and government authorities including public and government authorities outside your country of residence;
  • to protect our operations or those of any of our group companies;
  • to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and
  • to allow us to pursue available remedies or limit our damages.

Other 3rd parties

  • We may share personal data with emergency providers (fire, police and medical emergency services); retailers; medical organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business. To check information provided, and to detect and prevent fraudulent claims, personal data (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.

RETENTION OF YOUR INFORMATION

It is not possible for you to delete your profile from our database, nor is it feasible to delete all traces of your activity in the system. We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

SECURITY OF PERSONAL DATA

We will take all appropriate reasonable technical, legal and organizational measures, which are consistent with applicable privacy and data security laws to safeguard your personal data. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal data you might have with us has been compromised), please immediately notify us.

Where we provide personal data to a vendor, the vendor will be selected carefully and required to use appropriate measures to protect the confidentiality and security of your Personal Data.

LINKS TO THIRD PARTY SITES

Users will find advertising or other content on the Site that enable linking to the sites of Spear Technologies advertisers, Sponsors and other third parties. These third party sites may have their own privacy policies or no policy at all. Spear Technologies Privacy Policy does not apply to such other sites. Spear Technologies has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

Users should be aware that when they voluntarily disclose Personally Identifiable Information (for example, user name, e-mail address) on an Interactive Area of the Site, that information, along with any substantive information disclosed in your communication, can be collected and correlated and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond the control of Spear Technologies and Spear Technologies makes no warranties about the discoverability of your identity by methods beyond our control.

DISCLAIMERS AND OTHER INFORMATION

Information supplied by Spear Technologies is provided “as is” and neither Spear Technologies nor any of its agents, employees or representatives make any representation or warranty with respect to the contents of the site or information furnished by them or our agents, employees or representatives and specifically disclaim to the fullest extent permitted by law any and all warranties, express or implied, including, but not limited to, implied warranties of merchantability, completeness, timeliness, correctness, noninfringement, or fitness for any particular use, application or purpose.

By entering the site you hereby expressly agree that Spear Technologies, and its officers, directories, agents and employees, shall not be liable to you for any damages, claims, demands, or causes of action, direct or indirect, special, incidental, consequential or punitive, as a result of your use of the site or any information you obtain on it or any other interaction with Spear Technologies, in doing so, you agree that you are waiving voluntarily and unequivocally any liability of Spear Technologies.

Spear Technologies does not make any representation or warranty concerning errors, omissions, delays or other defects in the information supplied to users, or that its files are free of viruses, worms, Trojan horses or other codes that include or manifest contaminating or destructive characteristics.

With respect to communications to Spear Technologies, Spear Technologies does not guarantee that it will respond to all inquiries.

If any clause or provision set forth above is determined to be illegal, invalid or unenforceable under present or future law, then, in that event the clause or provision so determined to be illegal, invalid or unenforceable shall be severable without affecting the enforceability of all remaining clauses or provisions.

Any notice to Spear Technologies shall be given in writing and sent by certified and registered mail to, Attn: Privacy Officer, Spear Technologies, Inc., 145 Corte Madera Town Ctr. #186 Corte Madera, CA 94925, USA or by e-mail to privacy@spear-tech.com.

The application of these provisions, disclosures and disclaimers and all other matters arising from your use of this Site or of any information you obtain from Spear Technologies shall be governed by the laws of the United States of America and the State of California. Any claims, disputes or other controversies relating to or arising from these provisions, disclosures and disclaimers or from your use of this Site or any information you receive from Spear Technologies shall be brought exclusively in the United States District Court, the United States District Court for the Northern District of California, and you hereby expressly consent to the exercise of jurisdiction over you by such courts. YOU HEREBY ACKNOWLEDGE THAT THE PROVISIONS, DISCLOSURES AND DISCLAIMERS SET FORTH ABOVE ARE FAIR AND REASONABLE, AND THAT YOUR AGREEMENT TO FOLLOW AND BE BOUND BY THEM IS NOT THE RESULT OF FRAUD, DURESS OR UNDUE INFLUENCE EXERCISED UPON YOU BY ANY PERSON OR ENTITY. SPEAR TECHNOLOGIES MAKES NO REPRESENTATIONS, PROMISES, WARRANTIES OR UNDERTAKINGS CONTRARY TO THOSE SET FORTH ABOVE.

CALIFORNIA PRIVACY RIGHTS

(effective January 1, 2020)

This portion of our Privacy Policy advises California residents of rights provided in the California Consumer Privacy Act (“CCPA”) and how to effectuate those rights by communicating with us. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal data.

You may customize your data preferences or direct any rights requests or submit additional questions you may have regarding this Privacy Policy by regular mail sent to Attn: Privacy Officer, Spear Technologies, Inc. 145 Corte Madera Town Ctr. #186 Corte Madera, CA 94925

If you do, we will need to collect personal data and other information such as your name, email or transaction history in order to verify your identity.

Right to Deletion of Personal Data

California residents have the right to request the deletion of personal data as prescribed in Section 1798.105(a) of the CCPA. Spear Technologies may not delete some or all requested personal data as allowed or required by applicable law.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your personal data. Specifically, you may request to receive the specific pieces of personal data that we have collected about you.

You may also request to receive:

  • the categories of personal data that we have collected about you,
  • the categories of personal data that we have disclosed for a business purpose,
  • the categories of sources from which we collected the personal data,
  • our purposes for collecting that personal data, and
  • the categories of parties with whom we share your personal data.

Right to Opt-Out of Sale

We do not, and do not intend to, sell your personal data.

Right to not be Discriminated Against for Exercising CCPA Rights

We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.

Do Not Track

We treat the data of everyone who comes to our site in accordance with this Privacy Notice, regardless their “Do Not Track” setting.