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Privacybeleid

Revision 3
Effective November 21st, 2025


Emergence Software (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Emergence Software.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”) alongside our platform service, Sprucely.io. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, they are strictly defined as:

What information do we collect?

We collect information from you when you visit our website, register on our site, subscribe to our services or respond to and submit information to us through any of the associated pages on our site.

We do not collect any additional data from Google or Microsoft services.

When does Sprucely.io use end user information from third parties?

Sprucely.io will only collect End User Data necessary to provide the Sprucely.io services to our customers. We do not collect any End User Data from any third party services, including from any social media websites.

We do not use any additional end user information from Google or Microsoft services.

When does Sprucely.io use customer information from third parties?

We receive some information from third parties when you use the Sprucely.io services. For example, when you submit your email address to us to show interest in becoming a Sprucely.io customer, we receive information from a third party that provides automated fraud detection services to Sprucely.io. We will also receive events and updates related to your subscription status, as required to maintain the Sprucely.io service.

We do not use any additional customer information from Google or Microsoft services.

Do we share the information we collect with third parties?

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners in order to provide to us relevant marketing content, as well as financing institutions and government agencies for the sole purpose of acquiring funding, grants or other means of support explicitly to enhance the Sprucely.io service to our customers. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.

We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website, database storage and management, e-mail management, developing new product features, credit card processing, customer service and fulfilling orders and subscriptions. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website in a shared location, and type of the device used to visit the website. They may aggregate information about our advertising and what you see on the website and then provide auditing, research and reporting for us and our advertisers.

We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

We do not share any additional data from Google or Microsoft services with third parties.

Where and when is information collected from customers and end users?

Sprucely.io will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.

How do we use the information we collect?

Any of the information we collect from you may be used in one of the following ways:

How do we use your email address?

By submitting your email address on this website, you agree to receive emails from us. You can cancel your participation in email sendouts at any time by opting out of Communication in your Profile Settings. We only send emails to people who have authorized us to contact them, either directly, or through a third party. Exceptions to this opt-in policy are Sprucely.io e-mails that are part of the service to you or that was manually activated by you as a user (i e when you choose to share a Dashboard via email), as well as critical communication to you related to the security of the Sprucely.io service, or your account (i e when you use the Reset Password service to recover your acconut).

How long do we keep your information?

We keep your information only so long as we need it to provide Sprucely.io to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. We cannot, however, ensure or warrant the absolute security of any information you transmit to Sprucely.io or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

Could my information be transferred to other countries?

The Sprucely.io service and all of its associated data, including your End User Data and any additional data that you chose to upload to the Sprucely.io Cloud storage is hosted in the United States of America. Information collected via our website, through direct interactions with you, or from use of our help services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.

Is the information collected through the Sprucely.io Service secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Can I update or correct my information?

The rights you have to request updates or corrections to the information Sprucely.io collects depend on your relationship with Sprucely.io. Personnel may update or correct their information as detailed in our internal company employment policies.

Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.

Sale of business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Sprucely.io or any of its Corporate Affiliates (as defined herein), or that portion of Sprucely.io or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Sprucely.io, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Links to other websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Sprucely.io. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Payment details

We partner with Stripe, Inc to provide secure payments for the Sprucely.io service. The Stripe payment gateway is certified to PCI Server Provider Level 1 facilitating input, validation, storage and processing of your payment details, payments and subscriptions.

Cookies

Sprucely.io uses "Cookies" (alternatively Local and Session Storage) to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality like browsing between pages won’t work as seamless as you would like it to or you would be required to enter your login details every time you visit the website as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

Blocking and disabling cookies and similar technologies

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser's help menu for more information.

Remarketing services

We use remarketing services. In digital marketing, remarketing (or retargeting) is the practice of serving ads across the internet to people who have already visited your website. It allows your company to seem like they're “following” people around the internet by serving ads on the websites and platforms they use most.

Kids' privacy

We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from our servers.

Third-party services

We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third- Party Services").

You acknowledge and agree that Emergence Software Pte. Ltd. shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Emergence Software Pte. Ltd. does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

California residents

The California Consumer Privacy Act (CCPA) and California Online Privacy Protection Act (CalOPPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

We do not sell the Personal Information of our users.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

EU residents

We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under protection from being replicated or used in the wrong way.

What is General Data Protection Regulation (GDPR)?

GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and enhances the control the EU residents have, over their personal data.

The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.

What is personal data?

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.

The Data Protection Principles include requirements such as:

Why is GDPR important?

GDPR adds some new requirements regarding how companies should protect individuals' personal data that they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts it's simply the right thing to do. At Sprucely.io we strongly believe that your data privacy is very important and we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Sprucely.io as a Data Processor and Data Controller

Sprucely.io acts as a Data Processor when it receives information supplied by you as a user (i e when you supply your email address to us in order to create an account with Sprucely.io). Sprucely.io only collects the bare minimum information required to provide the Sprucely.io service to you. In fact, we only ask for your email address in order for you to use Sprucely.io. Optionally, and on your explicit action, Sprucely.io will process email addresses and messages to your respective contacts (i e when you share a Dashboard, or invite other users to the Sprucely.io service).

Sprucely.io acts as a Data Controller when it instructs any of our 3rd party providers to process a task required to fulfil the Sprucely.io service. We share your email address with Stripe, Inc in order to provide a means for you to chose a subscription plan and make payments for subscriptions through the Stripe payment gateway.

The duration of processing is valid throughout your active account period, and for the term and any period required to perform a party’s post-termination obligations.

Individual data subject's rights - data access, portability and deletion

We are committed to helping our customers meet the data subject rights requirements of GDPR. Sprucely.io processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days.

We are aware that as an EU customer, you have the right to access, update, retrieve and remove personal data. If you would like to exercise any of these rights, please contact us.

Governing law

This Privacy Policy is governed by the laws of the Republic of Singapore without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy.

The laws of the Republic of Singapore, shall govern this Agreement and your use of the website. Your use of the website may also be subject to other local, state, national, or international laws.

By using Sprucely.io or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

Your consent

We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and how it's being used. By using our Sprucely.io, registering an account, or subscribing to our service, you hereby consent to our Privacy Policy and agree to its terms.

Changes to our privacy policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.

Contact us

Don't hesitate to contact us if you have any questions.