Privacy

Spoke Software Privacy Policy

Spoke Software, Inc. ("Spoke Software" or "Spoke") believes that privacy is not just a feature or a legal document; it is the philosophy on which we founded the company. Concern for privacy permeates everything we build. This focus enables us to design software that we feel comfortable using and recommending to our own colleagues and family. Spoke Software provides tools and leverages information gathering techniques that allow registered users (also referred to as members) to leverage both their own relationships as well as the greater knowledge of the entire business community to find the right people at the right time.

Because Privacy is so important to us, Spoke Software is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.spoke.com and www.spokesoftware.com. Because we want to demonstrate our commitment to our users' privacy, we have agreed to disclose our privacy practices and have them reviewed for compliance by TRUSTe.

If users have questions or concerns regarding this statement, you should first contact Spoke via phone at 650-403-5900 or by submitting a message via our contact form. If you do not receive acknowledgment of your inquiry or it is not satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process. TRUSTe will serve as a liaison with the Web site to resolve users concerns. However, please understand the TRUSTe program covers only information that is collected through this Web site, and does not cover information that may be collected through software downloaded from the site.

Spoke Software is committed to protecting the privacy of Spoke's registered users and other individuals in the Spoke online Directory and Service. Following is the Spoke privacy statement outlining our policies governing the collection and use of registered user information and information in the Spoke online Directory and Service. If you have any questions regarding this policy, please contact Spoke Software via our contact form.

Registered User Information Collection & Use

Spoke Software requires users to register for the service and provide personal information including but not limited to the user's name, company, phone number and email address. Spoke uses this information to establish and deliver service to the individual. Spoke may use this information to contact registered users to notify them of product and service updates, provide instruction, and to deliver other service related information. Spoke may also contact registered users to request additional information and feedback. Spoke may employ companies and people to perform tasks on its behalf (such as for servicing registered user accounts), and may need to share personal information with these agents to establish and deliver service to registered users. Spoke's agents do not receive any right to use personal information about registered users beyond what is necessary to perform these tasks.

Name, title, and company are the primary identifiers used by the Spoke system and may be disclosed by voluntary registered user action on the Spoke service, including but not limited to completing a profile, a referral, or an information request. Direct contact information (including email, address, and telephone number) may only be made visible through the Spoke system by the action and with the permission of the registered user who already possesses such information. For more information on the operation of information requests and referrals, see the Referrals and Information Requests section below. Information collected about unregistered individuals is addressed in the Online Directory and Service Information Collection & Use section, below.

Spoke will not disclose registration information to third parties, including, but not limited to, companies affiliated with Spoke, without the registered user's consent or as otherwise stated in this privacy policy. If at some point Spoke sells all or a portion of its assets, customer information is an asset that may be transferred or acquired by a third party. The third party would then have the right to continue using the personal information solely as set forth in this policy. For more information, see our Privacy Policy Changes section below. Spoke may release or exchange personal information if required to do so to comply with applicable law, or to enforce its rights or agreements, or to prevent fraud. In addition, if you consent at the time of signup, Spoke may contact you to inform you of updates or new features. If you wish to be removed from such secondary mailings you may do so by the means provided in such email.

Spoke Software may automatically collect and analyze information regarding the use of Spoke's services and Spoke site activity. Information collected may include but is not limited to web site traffic volume, frequency of visits, type and time of transactions, type of browser and operating system, etc. This information is logged to help diagnose technical problems, administer the site, and improve the quality and types of service delivered. Spoke may also collect, track and analyze information that does not personally identify a user in aggregate form. This aggregate data will be used at Spoke's discretion and may be shared with third parties, but with no personally identifiable information attached.

Registered users can use the site to host relationship information in their SpokeBook (similar to an online contact list). Relationship information sent to Spoke servers by the registered user will remain the property – as between Spoke and the registered user - of the registered user. Spoke will not review, share, distribute or reference such data except as may be required to provide the requested Spoke services, or as provided in the Spoke Software Terms of Use Agreement, or as may be required by law.

We post customer testimonials on our web site which may contain personally identifiable information such as the customer's name, and we obtain the customer's consent prior to doing so.

Online Directory and Service Information Collection & Use

Spoke offers an online Directory that is available publicly via the Internet ("the Spoke Directory") and an online Service available only to registered users ("Spoke Service").

Spoke collects, aggregates and assembles information about businesses and business contacts from various sources, including:

• Publicly available information: Information that is available to the general public, including via the Internet.
• Published information: Information that has been privately collected by an entity other than Spoke, which is then made available for redistribution by that entity.
• Contributed information: Information contributed by members, including names, titles, and company affiliations of individuals. Information contributed by members also allows Spoke to learn email patterns and addresses. Personal contact information, including direct email addresses, is not made visible or posted for view by Spoke to the Spoke Directory or the Spoke Service.

The name, title history and company affiliation(s) of individuals that are obtained from any of the sources described above are made available to Spoke members and visitors to the Spoke.com website. Spoke also aggregates and publishes publicly available information about individuals, such as web references and published bios. Spoke members can also choose to publish their own Spoke Profile, which can contain a photo, professional and educational background, and interests.

Detailed contact information, such as direct email address or direct phone number, is not posted publicly by Spoke to the Spoke Directory or Spoke Service. If Spoke's technology is able to determine a person's company affiliation, then publicly available corporate contact information may be associated with that person, such as the corporate headquarters' address, corporate headquarters' phone number, and corporate email pattern.

Referrals and Connections

If a registered user elects to use Spoke's referral or connection service for reaching a person or company via the Spoke site, we will generate an email that can help them reach their target. When instructed to do so by a registered user, Spoke will automatically send the registered user's direct relationship an email inviting them to visit the site and help the person who contacted them. If the recipient does not respond, we send reminder emails only at the instruction of the registered user. Spoke does not make direct contact information visible publicly nor does Spoke provide it to registered users. Emails sent by Spoke at the behest of registered users are for the sole purpose of sending referrals or helping a registered user to expand his/her network.

Access and Correction of Registered User Personally Identifiable Information

If a registered user's personally identifiable information (such as zip code, phone, email or postal address) changes, or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate registered users' personally identifiable information and data the registered user has contributed to the Spoke system. Please be aware that even after your request for removal from our systems is processed, Spoke Software may for a time retain residual information about you and your relationship information in our backup and/or archival copies of our database (e.g., our records of deletion). Spoke will make reasonable commercial efforts to assure that such information is deleted as soon as possible following your request. Please see the Updating Information in Spoke's Online Directory and Online Directory and Service Opt Out Requests sections, below, for access and correction rights for unregistered individuals. Registered users may make changes to their personal information (generally effective upon submission) or seek a Personal Information Review via the "profile" page in their Spoke dashboard or by contacting support via a support request. If after trying these methods, you believe they are not effective, you may also send a letter seeking the necessary changes or deletions to the following address:

Spoke Software, Inc.
1670 South Amphlett Blvd., Suite 350
San Mateo, CA 94402
Attn: Personal Information Review

Access requests will be responded to within 30 days of receipt of the request.

Updating Information in Spoke's Online Directory and Service

Spoke provides a way for you to create your own personal profile ("Spoke Profile") that will be available any time a registered user or visitor views your information in the Spoke Directory or the Spoke Service. The information you provide in your Spoke Profile will override information aggregated about you by Spoke from the sources described above. However, if you do not update your Spoke Profile periodically, information that Spoke has gathered and aggregated about you may become available again. The information that you can choose to include in your Spoke Profile includes your picture, professional overview, professional experience, education, interests and favorite links. Click here to register and create your own Spoke Profile.

Opt Out Requests

If you no longer wish to receive promotional communications from Spoke, you may opt-out of receiving them by following the instructions included in each promotional communication, or by emailing us at opt-out@spoke.com, or by sending a letter requesting that you not receive specific communications to the following address:

Spoke Software, Inc.
1670 South Amphlett Blvd., Suite 350
San Mateo, CA 94402
Attn: Opt Out Requests

Users must be able to receive service-related communications in order to continue accessing the Spoke service.

Online Directory and Service Opt Out Requests

Because Spoke is constantly gathering information from publicly available sources and members, the best way to avoid having your information made visible via Spoke is to request removal or suppression of your information from public data sources (from which Spoke receives that information) and to actively make efforts to keep your personal information confidential whenever you are online.

Spoke voluntarily offers registered and unregistered individuals the opportunity to suppress their information from display in Spoke's online, public facing Directory and Spoke's members-only Service. Suppression means that information will be hidden from display on public areas of Spoke's website and/or the Service. Spoke retains some identification information in the Spoke database after receiving a suppression request (for suppression from both the Directory and the Service) for the sole purpose of maintaining an effective opt-out list to ensure that republication of this information does not occur.

For convenience, registered individuals can suppress their information directly from Spoke's online Directory by clicking here to verify their identity. Once logged in, registered users can then set their Profile display preferences in the ‘My Spoke' portion of the Spoke member site. Unregistered individuals may request suppression of their information by submitting a suppression request directly to Spoke by clicking here.

EU Safe Harbor

Spoke Software abides by the principles of the Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.

Cookies & Beacons

Spoke Software uses cookies and beacons to assist in delivering the service and to provide a positive and personalized registered user experience. Cookies are files sent to your browser from a web server and stored on your computer's hard drive. Our persistent and session ID cookies are used to identify unique visitors and to provide a personalized user experience. Other than user login and password information (which are stored on your computer if you select the "Login automatically" feature on the login page), we do not link the information we store in cookies to any personally identifiable information you submit while on our site. Beacons are bits of code that function similar to cookies. Our beacons are embedded in outgoing emails and generate a call back to the Spoke server when such emails are opened. Spoke uses beacons to track the status of sent emails.

Security

Spoke Software has implemented processes designed to protect user information and maintain security. Each registered user is assigned a unique user name and password which is required to access their account and relationship information. It is the user's responsibility to protect the security of his or her login information. Spoke's servers are located in secure server environments. Firewalls and other advanced security technologies are employed to prevent interference or access from outside intruders. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data.

Third Party Sites

Spoke's sites may contain links to third party web sites not associated with or controlled by Spoke, or to other sources of information about companies or individuals. Spoke Software is not responsible for the privacy practices or content of such sites or other information providers. Users will need to review the policy statements of these sites or information providers to understand their privacy policies.

Privacy Policy Changes

Spoke Software reserves the right to make changes to this privacy statement. Any material changes to this statement will be prominently posted online and accessible via the Spoke user portal 30 days prior to taking effect.

Effective 8/2003, Last Updated 4/23/2008