Sospes Privacy Policy

Your privacy is important to us. Please read this Privacy Policy to learn about the information that Sospes collects from you and how we use that information. BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.


This privacy statement presents our personal information policies and practices, including, but not limited to, the types of personal information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, and the information you will need to contact us or others to address your privacy concerns including the exercise of your rights.

“Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include, among others, name, physical address, email address, IP address, date of birth, social security number, driver’s license and passwords.

If you are using the Sospes’ software as an employee of an organization that currently has a Sospes subscription (a Customer), you should also refer to your organization’s own internal privacy policy, typically found as a part of your employment agreement. In this situation, Sospes processes this information as a data processor on behalf of its Customers in accordance with their requirements.

Sospes does not sell PII to any third parties – ever.  It is, however, necessary for us to have certain PII in order to provide you with information about Sospes’ products and services and to deliver those services to you.  In addition, we may share your PII we possess with our affiliates, business partners and third parties for the purposes of operating our business and delivering and improving the services we provide to you as well as for other legitimate purposes permitted by applicable law.  Your PII will not be shared with third parties for their marketing purposes.

Collection and Use of Personal Information

Our collection and use of PII is lawful. We will only use your information when we have a legitimate purpose for doing so and when doing so will not unduly affect your rights.

  • We will use your identity, contact and usage information to keep our records up to date, and to customize our site’s content to you. If you are a current user of our services, we may also use your contact and identity details to keep you up to date with our latest news such as product updates.
  • We will use your technical information to:
    • provide and make improvements to the site, system maintenance, support, reporting and hosting of data, and troubleshooting;
    • ensure that the site is secure;
    • analyze how users interact with the site; and
    • address any issues you may experience with the site.
  • We may need to comply with a legal or regulatory obligation:
    • Sospes may access and/or disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to:
      • conform to existing laws or to comply with legal process served properly on Sospes;
      • protect and defend the rights or property of Sospes; or
      • act under urgent circumstances to protect the personal safety of users of Sospes services or members of the public.
    • We need it to perform a contract or provide a service that you or your organization has asked for.  For example, we may need your contact information to respond to a question you have asked us via our website.

Sospes does not offer interactive services which allow minors to post content to share publicly or with friends. Sospes’ website is not intended for storing or transmitting ‘special categories’ of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or other topics that may be found on typical social media sites. 

There are two different ways in which Sospes interacts with individuals that determine what kinds of information Sospes collects and how that information is managed:

  1. Visitors to our website: Our website is where we provide information about Sospes’ products and services, answer inquiries, set appointments to discuss our products and services and generally manage communications with potential and current customers.
    Communications on our website are voluntary.  Sospes collects information from these communications, including PII, by requesting information on forms, from interactions including “chat” and through the use of third-party automated collection tools such as cookies that capture information sent from your web browser to our website. Information that is collected includes your IP address, the website address that you were at before landing at our website, and information such as the pages you clicked through while at our website. This information is collected to improve your experience and offer services to you. By visiting our website, you agree to our use of cookies. You can refuse the use of cookies by selecting the appropriate browser setting on your computer. If you refuse the use of cookies, please note that your experience using the site may not be optimal.
  2. Users of our software products and services. Access to Sospes’ software is only available to our customers and their employees, contractors, and other authorized users of Sospes products.  The data, including PII, we collect in our software is used only for providing and enhancing the services contracted by our customers, which is broadly for the purpose of managing systems in support of environmental, health, safety and sustainability programs.  Individual users’ ability to opt out of use of Sospes may depend on their employer’s policies and other regulatory compliance provisions.

You may be asked to provide your personal information anytime you are in contact with Sospes. Sospes and its affiliates may share this personal information with each other and use it in a manner consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any inquiries you may have.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect information such as occupation, language, zip code, area code, referrer URL, location, and the time zone where a Sospes product is used so that we can better understand customer behavior and improve our products, services, and advertising.
  • We may collect information regarding visitors activities on our website. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest to potential customers. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
  • We may collect and store details of how customers use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
  • With your explicit consent, such as when we are providing direct support, we may collect data about how you use your device and applications to help our developers improve our software.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Protection of Personal Information

Sospes operates using widely accepted technical and organizational measures to safeguard data. Sospes online services protect your PII with encryption while in transit and in storage.  When your personal data is stored by Sospes, we use computer systems with limited access housed in facilities using physical security measures.

When you post on a Sospes forum or chat room, personal information and content you share may be visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

In addition, we communicate our privacy and security guidelines to all Sospes employees and strictly enforce privacy safeguards within the company.

Retention of Personal Information

Sospes will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Location-Based Services

To provide location-based services on Sospes products, Sospes and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location.

Third-Party Sites and Services

Sospes’ website, products and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.  These companies are obligated to protect your information and may be located wherever Sospes operates.

Your Rights and Choices

Some governmental Privacy Laws provide consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

Right to Access Specific Information and Data Portability Right

You may have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.

Right to Delete

You may have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exercising Your Rights

To exercise the access, data portability and deletion rights described above, please contact our data privacy representative:

Only you, or a person appropriately authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or that person’s authorized representative and describe your request with sufficient detail to allow us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Sospes abides by the “safe harbor” frameworks set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected by organizations in the European Economic Area and Switzerland. Learn more about the U.S. Department of Commerce Safe Harbor Program.

Please note that personal information, including the information provided, regarding individuals who reside in a member state of the European Economic Area (EEA) and Switzerland is controlled by Sospes Distribution International in Cork, Ireland, and processed on its behalf by Sospes LLC. Personal information collected in the EEA and Switzerland when using iTunes is controlled by iTunes SARL in Luxembourg and processed on its behalf by Sospes LLC.

Representation for data subjects

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website:

Privacy Questions

If you have any questions or concerns about Sospes’ Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us.

All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Sospes may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

Sospes LLC, Colorado, USA.

Prighter certificate of Art 27 representation

Updated: 01/03/2023