Privacy Policy

Effective as of September 27, 2023.

Please click here to view the previous version of our Privacy Policy.

California Notice at Collection: See the California Privacy Notice section below for important information about your rights under applicable California privacy law.

SPMB, LLC (“SPMB,” “we,” “us,” or “our“) provides executive search services focused on the technology market. This Privacy Policy describes how SPMB processes personal information that we collect through our digital or online properties that link to this Privacy Policy (including, as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”)).

This Privacy Policy does not apply to information that we process on behalf of our clients (such as businesses and other organizations) while providing services to them. Our use of information that we process on behalf of our clients may be governed by our agreements with such clients. If you have concerns regarding your personal information that we process on behalf of a client, please direct your concerns to that client. In addition, this Privacy Policy does not cover information that we collect from our employees or job applicants, for which we may provide a separate privacy notice.

NOTICE TO EUROPEAN USERS: Please see the Notice to European users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Index

Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfers
Children
Changes to this Privacy Policy
How to contact us
California privacy notice
Notice to European users

Personal information we collect

Information you provide to us through the Service. This may include:

Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, and preferences.
Feedback or correspondence information, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Demographic information, such as your city, state, country of residence, and postal code. You may also provide us with protected classification characteristics though we do not ask for this information.
Professional/employment information, such as your current or former employer(s), employment dates, employment functions, employment locations, educational history, financial information such as your income, and any other information you may include on your resume or otherwise submit to us in connection with seeking employment opportunities.
Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications
Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Referrals. Users of the Service may have the opportunity to refer contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms (such as such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms) and other publicly available sources.
Our business partners, such as a business partner or individual who shares your information with us if you have expressed interest in learning specifically about our services, or the types of services we offer.
Marketing partners, such as joint marketing partners and/or event co-sponsors.
Data providers, such as information services and data licensors that provide demographic and other information

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device information, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area.
Online activity information, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.
Communication interaction information, such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, including information concerning choices you may have with respect to such technologies, see our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide and operate the Service, including connecting job seekers with businesses seeking applicants for executive employment opportunities;
provide information about our services;
establish and maintain your user profile on the Service;
communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
communicate with you about job opportunities;
communicate with you about events in which you participate
understand your needs and interests, and personalize your experience with the Service and our communications
provide support and maintenance for the Service
respond to your requests, questions and feedback.

Service improvement and analytics. We may use your personal information to:

analyze your usage of the Service, improve the Service, improve the rest of our business;
help us understand user demographics on the Service; and
develop new services.

Marketing and promotional communications. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes, including:

Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Interest-based advertising. We, our service providers and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your Choices section of our Cookie Notice.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes in they are not compatible with the initial purpose for which information was collected.

As part of these activities, we may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our organization. For more information on analytics, see our Cookie Notice.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your user profile.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at inquiries@spmb.com. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and similar technologies. For information about cookies employed by the Service and how to control them, see our Cookie Notice.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and Protection purposes.

To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use 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.

When we no longer require the personal information which we have collected about you, we may either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions, nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us at inquiries@spmb.com. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

SPMB, LLC

Email: inquiries@spmb.com (“Attn: Legal – Privacy”)
Mail: 80 Sir Francis Drake Blvd, STE 3F, Larkspur, CA 94939
Phone: +1 (415) 924-7200

Notice to California Residents

This section only applies to residents of California. For purposes of this section, personal information has the meaning given to “personal information” under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”). Please note that not all rights listed below may be afforded to all users and that if you are not a resident of California, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

In some cases, we may provide a different privacy notice to certain categories of residents of these states, in which case that notice will apply with respect to the activities it describes instead of this section.

Your privacy rights. You may have some or all of the rights listed below. However, these rights are not absolute, are subject to certain exceptions, and in certain cases we may decline your request as permitted by law.

Right to information/know. You can request the following information about how we have collected and used your personal information during the past 12 months:

o The categories of personal information that we have collected.

o The categories of sources from which we collected personal information.

o The business or commercial purpose for collecting and/or selling personal information.

o The categories of third parties with whom we have shared personal information (as “shared” is defined under the CCPA).

o Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third-party recipient.

o Whether we’ve sold your personal information (as “sell” is defined under the CCPA), and if so, the categories personal information sold to each category of third-party recipient.

Access. You can request a copy of the personal information that we have collected about you.
Correction. You can ask us to correct inaccurate personal information that we have collected about you.
Deletion. You can ask us to delete certain personal information that we have collected from you.
Opt-Out of “Sales” and “Sharing”. You have the right to opt-out of “sales” or “sharing” of personal information (as such terms are defined under the CCPA).
Opt-in. We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age.
Sensitive Personal Information. You have the right to limit certain uses or disclosures of sensitive personal information (as such term is defined under the CCPA); [however, we do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.]
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of refusal to provide the Services or legally prohibited changes to the price or quality of the Services.

Exercising your right to information/know, access, correction, and deletion. You may submit requests to exercise your right to information/know, access, correction, or deletion by visiting https://spmb.com/california-residents-do-not-sell-my-information/, calling us toll free at 1-844-281-5681, or emailing inquiries@spmb.com.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The CCPA may classify our use of some of these services as “selling” or “sharing” your personal information with the advertising partners that provide the services. You can submit requests to opt-out of such sales and sharing of personal information here: Do Not Sell or Share My Personal Information, via phone by calling 1-844-281-5681, or by broadcasting the global privacy control signal. [INSERT RELEVANT OPT-OUT PREFERENCE SIGNAL DETAILS].

Verification of Identity; Authorized Agents. We reserve the right to confirm your residency to process your requests and will need to confirm your identity to process your requests to exercise your information/know, access or deletion rights. As a part of this process, government identification may be required.

Consistent with applicable law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Retention. See the Retention section, above, for information concerning our retention of each category of personal information identified below.

Deidentification. We do not to attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Personal information that we collect, use and disclose. The chart below summarizes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the chart refer to the categories of information, statutory categories, and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. The categories of sources from which the personal information is or was collected and the business or commercial purposes for collecting such information are as described in the “Personal information we collect” and “How we use your personal information” sections above.

Personal Information	Statutory category of personal information (PI)	Categories of third parties to whom we “disclose” the PI for a business purpose	Categories of third parties to whom we “sell” the PI
Business and personal contact information	· Identifiers · Commercial information · California customer records	· Affiliates · Service providers · Linked third-party services · Advertising partners · Third parties designated by you · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Profile information	· Identifiers · Commercial information · California customer records	· Affiliates · Service providers · Linked third-party services · Advertising partners · Third parties designated by you · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Transactional information	· Identifiers · Commercial information · California customer records · Financial information	· Affiliates · Service providers · Third parties designated by you · Professional advisors · Authorities and others · Parties involved in corporate transactions	· N/A
Feedback or correspondence information	· Sensory information · Commercial information · California customer records	· Affiliates · Service providers · Third parties designated by you · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· N/A
Demographic information	· Identifiers · California customer records	· Affiliates · Service providers · Third parties designated by you · Advertising partners · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Professional/employment information	· Identifiers · Professional or employment information · Education information	· Affiliates · Service providers · Linked third-party services · Third parties designated by you · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Usage information	· Identifiers · Commercial information · California customer records · Internet or network information	· Affiliates · Service providers · Third parties designated by you · Advertising partners · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Marketing information	· Identifiers · Commercial information · California customer records · Internet or network information	· Affiliates · Service providers · Third parties designated by you · Advertising partners · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Device information	· Identifiers · Internet or network information	· Affiliates · Service providers · Linked third-party services · Advertising partners · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Online activity information	· Identifiers · Commercial information · Internet or network information	· Affiliates · Service providers · Linked third-party services · Advertising partners · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)
Communication interaction information	· Identifiers · Commercial information · California customer records · Internet or network information	· Affiliates · Service providers · Linked third-party services · Advertising partners · Other users of the Service · Professional advisors · Authorities and others · Parties involved in corporate transactions	· Advertising partners (to facilitate online advertising)

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.

Notice to European Users

General

Where this Notice to European users applies. The information provided in this “Notice to European Users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR (see below)) – i.e., information about individuals from which they are either directly identified or can be identified. The personal information that we collect from you is identified and described in greater detail in the section “Personal information we collect”.

Controller. SPMB is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is DataRep. You can contact them:

By email to: datarequest@datarep.com.
By postal mail to: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Contact form: https://www.datarep.com/data-request/?dpr=

Our Representative in the UK. Our UK representative appointed under the UK GDPR is DataRep. You can contact them:

By email to: datarequest@datarep.com.
By postal mail to: DataRep, BPM 335368, 372 Old Street, London, EC1V 9AU, United Kingdom
Contact form: https://www.datarep.com/data-request/?dpr=

When mailing inquiries, it is essential that you mark your letters for “DataRep” and not “SPMB LLC”, or your inquiry may not reach the correct destination. Please also quote “SPMB LLC” in the subject line of any communication sent to DataRep and refer clearly to SPMB LLC in your correspondence with DataRep.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract which we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	· Business and personal contact information · Profile information · Registration information · Feedback and correspondence information · Demographic information · Employment information · Financial information · Usage information · Marketing information	· Contractual Necessity
Service improvement and analytics	· Business and personal contact information · Profile information · Demographic information · Feedback and correspondence information · Device information · Online activity information · Communication interaction information	· Legitimate Interests. We have a legitimate interest in providing you with a good service and improving the Service and our developing and growing our organisation. · Consent, in respect of processing directly associated with any optional cookies used for this purpose.
Marketing and promotional communications	· Business and personal contact information · Demographic information · Demographic information · Marketing information · Third-party information	· Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. · Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	· Any and all data types relevant in the circumstances	· Compliance with Law. · Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. Also, we and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Data sharing in the context of corporate transactions	· Any and all data types relevant in the circumstances	· Legitimate Interests. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate transaction (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
With your consent	· Any and all data types relevant in the circumstances	· Consent.
Further uses	· Any and all data types relevant in the circumstances	· The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. · Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your deletion request for specific legal reasons. We will notify you of these, if applicable, at the time of your request.
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to inquiries@spmb.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

SPMB is a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision.

o We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection.

o However, in these cases:

we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us.