Privacy Policy

Who We Are and What This Policy Covers

Spartera, Inc. ("Spartera," "we," "us," or "our") operates a data commerce platform connecting data sellers with analytics buyers. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our websites (spartera.com, marketplace.spartera.com, app.spartera.com), create an account, buy or sell through the Spartera Marketplace, use our APIs, or otherwise interact with us.

This Policy covers the personal information that Spartera controls: information about our visitors, Buyers, Sellers, and their authorized users. It does not govern the data products, analytics, or Source Data that Sellers offer through the Marketplace. Marketplace products may not contain personal data under our Terms of Service and Platform Partner Agreement, and where Spartera hosts Seller Source Data under the Custodian Model, Spartera acts as a data processor on the Seller's behalf under our Data Processing Addendum, not under this Policy.

Information We Collect

We collect the following categories of personal information:

• Account information: When you sign in using Google or Microsoft Single Sign-On, we receive your name, email address, and basic profile information from your identity provider. We do not receive or store your Google or Microsoft password.
• Business and profile information: Company name, role, and information you add to your Buyer or Seller profile, including Stripe Connect onboarding status for Sellers.
• Transaction information: Credit purchases, product usage events, payout records, and billing history. Payments are processed by Stripe; Spartera does not store full payment card numbers.
• Usage and device information: API request logs and usage metering, IP address, browser type, device identifiers, pages visited, and interactions with our websites and applications.
• Communications: Information you submit through contact forms, demo requests, newsletter signups, support tickets, and reviews or other content you post.
• Cookies and analytics data: Information collected through cookies and similar technologies, including Google Analytics, as described in Section 7 and our Cookie Policy.

How We Use Personal Information

We use personal information to:

• Provide, operate, and secure the platform, including authentication, query routing, usage metering, billing, and Seller payouts
• Process transactions and maintain accurate financial, tax, and audit records
• Detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Service, including screening required by U.S. sanctions, export control, and data security laws
• Respond to inquiries and provide customer support
• Send transactional and service messages (such as purchase confirmations, payout notifications, and material terms changes), which you receive regardless of marketing preferences
• Send marketing communications, which you can opt out of at any time as described in Section 8
• Analyze usage to improve our products, develop new features, and understand marketplace performance
• Comply with legal obligations and enforce our agreements

Marketplace Data and Our Role

Spartera is a marketplace platform, not a data broker. Our platform architecture is designed so that Seller data remains in Seller-controlled infrastructure: analytics queries execute in the Seller's environment, and for API data products Spartera acts as an authenticated routing and metering layer that does not store, cache, or retain the content returned by Seller endpoints.

Products distributed through the Marketplace may not contain personal data. Our Terms of Service and Platform Partner Agreement prohibit Sellers from including personal information, protected health information, or sensitive data in any product, analytics output, or endpoint response delivered to Buyers, and prohibit Buyers from attempting to re-identify any individual from purchased analytics.

We never share a Buyer's personal information with Sellers. Sellers receive only anonymous, aggregated statistics about how their products perform.

How We Share Personal Information

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising. We disclose personal information only in the following circumstances:

• Service providers and processors: Companies that perform services on our behalf under contractual confidentiality and data protection obligations, including Stripe (payment processing and Seller payouts), Google Cloud Platform (hosting and infrastructure), Google and Microsoft (single sign-on), Google Analytics (site analytics), and email and support tooling providers
• Aggregate reporting to Sellers: Anonymous, aggregated usage statistics that do not identify any individual Buyer
• Legal and safety: When required by law, subpoena, or legal process; to enforce our agreements; or to protect the rights, property, safety, or security of Spartera, our users, or the public
• Corporate transactions: In connection with a merger, acquisition, financing, or sale of assets, subject to this Policy or equivalent protections
• With your direction or consent: When you ask us to share information or otherwise consent to a disclosure

Your U.S. State Privacy Rights

Depending on your state of residence, you may have the right to: (a) know and access the personal information we hold about you; (b) correct inaccurate personal information; (c) delete your personal information; (d) obtain a portable copy of your personal information; (e) opt out of the sale of personal information, sharing for targeted advertising, and certain profiling; and (f) not receive discriminatory treatment for exercising your rights. Because we do not sell personal information or share it for targeted advertising, the opt-out rights in clause (e) are honored by default.

To exercise any of these rights, email legal@spartera.com with the subject line "Privacy Rights Request," or use the contact form on this site. We will verify your request using the email address associated with your account or submission, respond within 45 days (extendable once by 45 days where permitted, with notice), and will not charge a fee for a first request in any 12-month period. You may use an authorized agent to submit a request on your behalf; we will require proof of the agent's authority and verification of your identity.

If we decline to act on your request, you may appeal by replying to our decision with the subject line "Privacy Appeal." We will respond to appeals within the timeframe required by your state's law. If your appeal is denied, you may contact your state Attorney General.

Our websites recognize and honor the Global Privacy Control (GPC) browser signal as a valid opt-out preference in states where recognition is required.

Cookies and Analytics

We use essential cookies that are necessary for the operation and security of our websites, and analytics cookies (including Google Analytics) that help us understand how visitors use our sites. Analytics data is used for our own product and site improvement, not for cross-context behavioral advertising.

You can control cookies through your browser settings, opt out of Google Analytics using Google's browser add-on, and send a Global Privacy Control signal, which we honor as described in Section 6. For details about the specific cookies we use and their durations, see our Cookie Policy.

Marketing Communications

If you create an account, complete a transaction, or submit your information through our forms, we may send you marketing communications about our products, platform updates, and industry insights. You can opt out at any time by clicking "unsubscribe" in any marketing email, emailing hello@spartera.com with "Unsubscribe" in the subject line, or updating your communication preferences in your account settings. Opting out of marketing does not affect transactional or service messages, such as purchase confirmations, payout notifications, security alerts, or notices of material changes to our terms.

Residents of the EEA, United Kingdom, and Other Jurisdictions

Where the EU or UK General Data Protection Regulation applies, Spartera, Inc. is the data controller for the personal information described in this Policy, and we process personal information on the following legal bases: performance of a contract (providing the platform, processing transactions, and remitting payouts); legitimate interests (securing the platform, preventing fraud, improving our services, and business-to-business marketing, balanced against your rights); consent (where required, for example for certain cookies or marketing, which you may withdraw at any time); and compliance with legal obligations.

In addition to the rights described in Section 6, you may have the right to object to or restrict processing, to withdraw consent, and to lodge a complaint with your local supervisory authority (in the UK, the Information Commissioner's Office).

Our services are hosted in the United States, and personal information is processed there. Where we transfer personal information from the EEA, UK, or Switzerland, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and the UK Addendum or International Data Transfer Agreement, as applicable. You may request a copy of the relevant safeguards by contacting us.

Data Retention

We retain personal information for as long as your account is active and as needed to provide the services, and afterward for as long as necessary to comply with legal, tax, accounting, and audit obligations, resolve disputes, enforce our agreements, and maintain security. Transaction and payout records are retained as required by financial regulations. When personal information is no longer needed, we delete it or de-identify it, and residual copies in routine backups are removed in accordance with our backup retention schedule.

Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, authenticated single sign-on, cloud infrastructure security controls in Google Cloud Platform, and internal security testing aligned with our compliance program. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and regulators as required by applicable law.

Children's Privacy

Our websites and services are intended for business use by adults. They are not directed to individuals under 18, and we do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us personal information, contact us at legal@spartera.com and we will delete it.

Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page indicates when it was last revised. If we make material changes, we will provide notice on our websites or by email before the changes take effect. Your continued use of our services after the effective date of an updated Policy indicates your acknowledgment of the changes.

Contact Us

If you have questions about this Privacy Policy, our privacy practices, or your rights, contact us at legal@spartera.com or by mail at: