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Privacy Policy 

1. Introduction

1.1 Our Commitment to Privacy
At Spedy ("we," "us," or "our"), we understand that privacy is not only a fundamental right but also a cornerstone of the trust our users place in us. We are deeply committed to protecting the personal information entrusted to us and ensuring that it is handled with the utmost care, security, and respect. This commitment extends to every individual who interacts with our application, including visitors exploring our services, registered users, individual customers, and representatives of our corporate clients.

We take seriously the responsibility of safeguarding personal data against unauthorized access, disclosure, or misuse. Our privacy practices are designed to exceed expectations, ensuring that all data is collected, processed, and stored with transparency and accountability. We continuously evaluate and enhance our security measures to provide a robust level of protection against emerging risks.

At the heart of our approach to privacy is a dedication to fostering trust and confidence among those who engage with us. By upholding integrity and respecting individual privacy, we aim to create long-lasting relationships that reflect our commitment to treating personal data with the care it deserves. Whether you are a casual visitor or a long-term customer, your privacy is our priority.

As part of this commitment, Brydge Holdings LLC ("Spedy," "we," "us," or "our") adheres to stringent international privacy standards and complies with the data protection laws of the regions where we operate. These include regulations in Panama, Canada, and other jurisdictions with robust privacy frameworks. This Privacy Policy is designed to provide clear, comprehensive information about how we collect, use, and safeguard your personal data, ensuring compliance with applicable laws while prioritizing your rights and interests.

Our mission is to uphold the highest standards of privacy protection while delivering exceptional services. We invite you to read this Privacy Policy carefully to understand how your data is handled, and we encourage you to reach out with any questions or concerns. Your trust drives our commitment to privacy, and we are honored to safeguard your information.

1.2 Scope of This Privacy Policy

This Privacy Policy provides a comprehensive overview of how Spedy, managed by Brydge Holdings LLC, handles your personal data when acting as a "data controller." As a data controller, we hold the responsibility of determining the purposes for which personal data is collected and processed, as well as the methods by which this processing occurs. This significant role underscores our commitment to complying with all applicable data protection laws, including those governing privacy rights, data security, and lawful data handling practices.

This policy applies to all interactions with our application, associated services, and supporting systems where personal data is involved. It serves as a framework for our data management practices, detailing how we collect, use, store, and share personal information. Our approach to data handling emphasizes:

  • Respect for Your Privacy: Ensuring that your personal data is processed with care and integrity at every stage of your interaction with us.

  • Transparency: Clearly communicating how your data is managed and why it is collected.

  • Security: Employing robust safeguards to protect your data from unauthorized access or misuse.

  • User Empowerment: Informing you of your rights and the choices available to you regarding your data.

This Privacy Policy serves to provide you with a clear understanding of your rights, the ways in which your data is processed, and the steps we take to protect your information. We are dedicated to ensuring that your personal data is processed only for legitimate purposes, aligned with your expectations and the requirements of relevant legal frameworks.

Scope and Applicability

This Privacy Policy applies to the Spedy application, and all related services provided by Brydge Holdings LLC. Our practices are designed to meet and exceed international privacy standards, with a specific focus on compliance in regions where we operate, including:

  • Panama: We adhere to the provisions of Law 81 of 2019 on the Protection of Personal Data, ensuring that your data is collected, processed, and secured in compliance with Panamanian legal requirements.

  • Canada: We comply with Canada’s federal data protection law, the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as applicable provincial laws, to uphold rigorous standards for the collection, use, and sharing of personal information.

  • Other International Regions: For jurisdictions outside Panama and Canada, we ensure adherence to applicable laws and regulatory standards, implementing safeguards to protect your data wherever you are located.

Our Responsibilities as a Data Controller

As a data controller, our responsibilities include:

  1. Defining Processing Purposes: Clearly identifying and documenting the specific reasons for collecting and processing your data, ensuring these purposes are lawful and necessary.

  2. Ensuring Lawful Processing: Conducting all processing activities in compliance with applicable data protection regulations, such as GDPR, PIPEDA, or Law 81 of 2019.

  3. Maintaining Security Standards: Implementing robust technical and organizational measures to protect your data against unauthorized access, breaches, or misuse.

  4. Facilitating User Rights: Providing mechanisms for you to access, correct, or delete your data and exercise other rights granted under relevant privacy laws.

Your Agreement and Responsibilities

By using our application or services, you acknowledge and agree to this Privacy Policy. It is your responsibility to review this policy regularly, as we may update it periodically to reflect changes in our practices, technologies, or legal requirements. Significant updates will be communicated to you through appropriate channels, such as email notifications or in-app alerts.

If you do not agree with this Privacy Policy, we encourage you to discontinue the use of our services. However, should you have any concerns or questions, we welcome you to contact us directly, and we will make every effort to address your inquiries promptly and transparently.

Commitment to Privacy Excellence

At Spedy, safeguarding your personal data is more than a legal obligation—it is a fundamental part of our mission to provide exceptional, trustworthy services. By aligning our practices with rigorous international privacy standards, we aim to create an environment where your privacy is respected, your data is secure, and your trust in us is well-placed.

For any questions or additional information regarding this Privacy Policy, please refer to the contact details provided in Section 10 of this document.

1.3 Privacy Controls
Our application is designed with comprehensive privacy controls that empower you to manage the way your personal data is handled. These controls are a critical part of our commitment to transparency and user autonomy. With these features, you can:

  • Marketing Preferences: Choose whether to receive marketing communications, giving you the option to opt in or out at any time.

  • Data Collection and Sharing: Decide what personal information is collected and how it may be shared with third parties.

  • Data Visibility and Publication: Control the visibility and publication of your personal information to ensure it aligns with your privacy expectations.

These privacy controls are intuitive and easily accessible, allowing you to tailor your settings to meet your specific needs. By providing these tools, we aim to give you complete control over your personal data and ensure that your preferences are respected.

1.4 Use of Cookies
Cookies are used on our application to enhance its functionality, improve performance, and deliver a more personalized user experience. Cookies allow us to:

  • Remember Your Preferences: Enable features like language selection, saved login credentials, and customized settings.

  • Optimize Functionality: Improve the overall performance of our application by understanding how users interact with it.

  • Deliver Tailored Experiences: Provide recommendations or content that aligns with your preferences.

It’s important to note that essential cookies, which are necessary to deliver our core services, are always active to ensure seamless operation. However, for non-essential cookies, such as those used for analytics, performance tracking, or marketing purposes, we will request your consent when you first visit our site.

You have the ability to manage your cookie preferences through our application’s privacy settings or your browser settings at any time, ensuring you have full control over how cookies interact with your experience.

1.5 Definitions
To provide clarity and consistency throughout this policy, the following definitions apply:

  • "We," "us," and "our" refer to Spedy, the entity responsible for managing and safeguarding your personal data.

  • "Personal Data" refers to any information that relates to an identified or identifiable individual, including names, contact information, account details, and more.

  • "Data Controller" means Spedy, as the organization that determines how and why personal data is processed.

  • "Cookies" are small data files stored on your device that help improve functionality and enhance your experience on our application.

For detailed contact information or inquiries regarding this policy, please refer to Section 9. We encourage you to reach out if you have questions, require clarifications, or need further assistance regarding our privacy practices.

2. Personal Data We Collect

2.1 Overview of Data Categories

We collect and process various categories of personal data to enhance and provide seamless functionality to our services and application, improve user experience, ensure security, prevent fraud, and meet legal obligations. This data is gathered through your interactions with our application and services, including account registration, transactions, communication, or technical engagement. By maintaining transparency, we aim to provide clarity about the types of data collected, their purposes, and our commitment to processing them responsibly.

This section outlines the key categories of personal data we handle. In cases where data is not directly obtained from you, we will identify the source and specify the type of information collected. By maintaining transparency, we aim to give you full visibility into how your personal data is gathered and processed.

The types of data we collect depend on your interactions with our application, such as creating an account, making transactions, or contacting us for support. The data collected is used for purposes outlined in this policy, including account management, service delivery, and compliance with legal requirements. All data collected is handled in compliance with applicable laws and is used solely for legitimate purposes. In cases where information is not obtained directly from you, we identify the source, and the type of data received. Below is a detailed breakdown of the types of personal data we process.

2.2 Contact Data

Contact data enables us to identify and communicate with you effectively. This includes:

  • Personal Information: Such as your full name, email address, phone number, and profile details.

This information is provided directly by you during account registration, profile updates, or interactions with us, such as submitting inquiries.

Contact data is essential for sending notifications, providing customer support, and ensuring personalized user interactions.

2.3 Identity and Verification Data
To maintain the integrity of our platform and prevent fraudulent activities, we collect and process data necessary for identity verification. This includes:

  • Photographic Identifiers: Selfies and profile pictures are used for identity confirmation and account personalization.

  • Government-Issued IDs: Documents such as driver’s licenses or national identification cards are required for account verification. Other forms of government-issued identification, such as passports, may be accepted on a case-by-case basis, depending on the specific circumstances.

  • Location Data: Geographical information collected via device settings helps validate activity, provide region-specific services, and prevent unauthorized access or fraudulent activities.

This data is essential for ensuring the safety and security of all users on our platform. We process all identity and verification data securely and in strict compliance with applicable laws and standards, safeguarding the trustworthiness of our platform.

2.4 Transaction Data
Transaction data involves financial information necessary for processing payments and facilitating financial activities securely and transparently. It includes:

  • Payment Information: Such as credit card details, bank account numbers, or third-party payment service credentials. This data is handled exclusively by PayPal and Stripe on our behalf, ensuring secure processing.

  • Transaction Records: Details about transactions conducted through the app, including the date, amount, and item descriptions.

  • Personal Information: Contact details, such as your name and email, used to confirm orders or process payments.

Important Note: Spedy does not access or store sensitive payment details directly. PayPal and Stripe manage all financial transactions, and their terms must be accepted to use the Spedy application.

Transaction data is used to process payments, confirm orders, generate receipts, and maintain a record of financial activities for both operational and regulatory purposes.

2.5 Communication Data

Communication data encompasses all messages and correspondence exchanged between you and us to facilitate interactions, resolve issues, and ensure accountability. This includes:

  • Message Content: Text, attachments, and other content you share when contacting us via email, in-app messaging, live chat, or social media.

  • Metadata: Information automatically generated during communication, such as timestamps, sender and recipient details, communication channels, and associated identifiers (e.g., user ID).

  • Contact Form Data: Details submitted via forms on our application, including your name, email address, subject, and message body.

We collect communication data to facilitate effective interaction, provide timely responses to inquiries, resolve support requests, and improve customer service quality. Additionally, this data may be used for quality assurance, training, or maintaining a record of correspondence for accountability and transparency.

Rest assured that all communication data is handled securely and is never shared externally without your consent unless required by law. Any communication exchanged between users, such as calls or messages within the app, remains private and is not disclosed to Spedy or Brydge Holdings. However, we encourage users to exercise caution when sharing personal information during in-app communications.

2.6 Usage Data

Usage data provides insights into your interactions with our application and services. This category includes:

  • Geographical Information: Approximate location information derived from device settings, helping us provide region-specific services and security measures.

  • Interaction Logs: Detailed records of your activity within our application, including features accessed, buttons clicked, and session durations.

  • Performance Metrics: System data that measures application performance during your interactions, helping us identify and resolve technical issues.

This data is automatically collected through analytics tools and is essential for optimizing our application’s functionality, ensuring security, and improving user experience. Usage data also helps us analyze trends, monitor system performance, and implement updates or features that align with user preferences.

This information is anonymized wherever possible to protect your privacy while enabling meaningful insights.

2.7 Review Data

Review data consists of the feedback, evaluations, and ratings you provide about your experiences with our application or services. Your feedback plays a vital role in shaping our platform. This includes:

  • User-Generated Feedback: Ratings, comments, suggestions, testimonials, or reviews submitted via feedback forms, surveys, email, or public review platforms.

  • Ratings and Scores: Numerical or qualitative assessments of our services, features, or products, typically provided alongside reviews.

  • Supplementary Context: Information about your interactions with our services that you may include in your reviews, such as specific features used or challenges encountered.

We process review data to understand user satisfaction, identify strengths, and uncover areas for improvement. Your feedback plays a pivotal role in shaping the development and enhancement of our application. By analyzing trends in review data, we can implement targeted updates, introduce new features, and address any concerns to better meet your needs.

Additionally, anonymized or aggregated review data may be shared internally for product development purposes or externally (e.g., on our website or promotional materials) to showcase user satisfaction. Your individual reviews will never be published without your explicit consent.

2.8 Third-Party Data Handling
To provide essential services and enhance the functionality of our platform, we work with trusted third-party partners. These relationships are integral to delivering a secure and seamless user experience. Key third-party partnerships include:

  • Payment Processors: PayPal and Stripe are responsible for securely managing all payment-related data. Spedy does not access or store sensitive payment information, ensuring compliance with the highest privacy and security standards.

  • Brydgee Service Providers: Users may interact directly with Brydgee partners within the app for transaction purposes. Information shared during these communications remains private and is not disclosed to Spedy or Brydge Holdings.

We ensure that all third-party interactions are governed by robust agreements designed to protect user privacy and guarantee secure handling of all data.

2.9 Data Security and Privacy Assurance
We prioritize the protection of your personal data. Measures include encryption, secure storage protocols, and stringent access controls. While we strive to maintain the highest security standards, users are encouraged to protect their accounts by using strong passwords and avoiding sharing sensitive information in public spaces or untrusted communications.

By providing this revised overview, we ensure our data collection practices are transparent and aligned with the features and operations of our application. If you have further questions or need additional clarification, please contact our support team.

Through this extended breakdown, we aim to assure you of our commitment to using communication, usage, and review data responsibly to enhance your experience with our application and services.

3. Purposes of Processing and Legal Bases

3.1 Purpose Overview
This section provides a detailed explanation of why we process your personal data and the legal justifications supporting each type of processing activity. By outlining these purposes, we aim to demonstrate our commitment to transparency and compliance with data protection regulations. Each processing activity is aligned with one or more legal bases to ensure your rights and interests are upheld.

3.2 Operations
We process your personal data to enable the effective functioning of our application and services. Key operational activities include:

  • Service Delivery: Ensuring the smooth operation of our application and fulfilling your requests for services or features.

  • Billing and Payments: Generating accurate invoices, processing transactions securely, and managing credit control to ensure timely payments and financial accuracy.

  • Technical Support: Monitoring and resolving technical issues to maintain uninterrupted service.

  • Security and Fraud Prevention: Implementing measures to detect and prevent unauthorized access, fraud, and other security threats.

The legal basis for this processing is our legitimate interest in running a well-managed, efficient business. These activities are essential to deliver reliable and high-quality services while safeguarding the interests of both our users and our organization.

3.3 Publications
In specific cases, we may process account data to facilitate the publication of content or materials on our platform at your request. This includes:

  • User-Generated Content: Publishing reviews, testimonials, or other content you contribute voluntarily.

  • Public Profiles: Displaying elements of your profile, such as your name or username, to foster interaction and engagement within the user community.

  • Knowledge Sharing: Sharing insights, case studies, or examples (with your explicit consent) to support collaborative learning or demonstrate success stories.

This processing is based on your consent, which you can withdraw at any time, and/or our legitimate interest in encouraging meaningful interactions and transparency within our platform. These activities help build trust among users and enhance the value of our services.

3.4 Relationships and Communications
We process contact, account, transaction, and communication data to maintain effective relationships with our users and facilitate seamless communication. This includes:

  • Customer Support: Managing inquiries, troubleshooting issues, and providing timely assistance to users.

  • Relationship Management: Maintaining ongoing relationships by sending non-marketing communications, such as transactional updates, service notifications, or policy changes.

  • Feedback and Improvement: Gathering insights from your communications to identify areas where our services can be enhanced.

The legal basis for this processing is our legitimate interest in ensuring strong relationships with our users, fostering trust, and delivering exceptional customer experiences. These activities are critical to ensuring your needs are met and that our services remain reliable and user centric.

3.5 Direct Marketing
We may process personal data to provide you with targeted marketing communications tailored to your preferences. This involves:

  • Promotional Messages: Sending newsletters, offers, or updates about products and services that align with your interests.

  • Personalization: Using data such as your preferences or past interactions to ensure that marketing content is relevant to you.

  • Opt-In and Management: Allowing you to opt in to marketing communications and manage your preferences easily at any time.

The legal basis for this processing is your consent, which is explicitly obtained when you subscribe to marketing communications. In some cases, our legitimate interest in promoting our services may also apply, provided this does not infringe on your privacy rights. You always have the option to withdraw your consent or object to marketing communications.

Additional Notes on Legal Bases:
In circumstances where processing is based on legitimate interest, we carefully balance our interests with your rights to ensure that our actions are lawful, necessary, and respectful of your privacy. Similarly, where consent is the legal basis, we ensure that it is freely given, specific, informed, and revocable at any time.

By aligning our processing activities with clearly defined purposes and legal bases, we are committed to operating transparently and in full compliance with applicable data protection laws while prioritizing your privacy and trust.

3.6 Research and Analysis

We process usage and transaction data to conduct research and analysis that supports the continuous improvement of our services. These activities are designed to enhance the user experience, optimize performance, and guide our strategic decisions. Specifically, this includes:

  • Understanding User Behavior: Analyzing patterns in how users interact with our application to identify trends, preferences, and areas for enhancement.

  • Improving Functionality: Using insights derived from analysis to refine features, address pain points, and create a seamless user experience.

  • Business Strategy Development: Employing data-driven insights to inform product development, service expansions, and overall business growth.

The legal basis for this processing is either your consent, obtained when you agree to participate in research initiatives or data collection, or our legitimate interest in advancing our services through evidence-based improvements. Any research or analysis is conducted responsibly, with a strong emphasis on data anonymization and user privacy.

3.7 Record Keeping

We retain personal data as part of our obligation to maintain accurate and necessary business records. This processing supports several critical operations, including:

  • Regulatory and Legal Compliance: Ensuring adherence to laws and regulations that mandate specific record retention periods.

  • Audit and Reporting: Preparing for financial audits, compliance checks, and internal performance assessments.

  • Operational Continuity: Maintaining a reliable archive of transactions, communications, and interactions to ensure efficient business operations.

  • Dispute Resolution: Preserving records to address user inquiries, resolve disputes, or respond to legal or regulatory challenges.

The legal basis for this processing is our legitimate interest in upholding efficient and compliant business practices. All retained data is securely stored and periodically reviewed to ensure that records are only kept for as long as necessary.

3.8 Security

We process personal data to enhance security measures and protect our systems, users, and operations. This involves:

  • Fraud Detection and Prevention: Identifying suspicious activity, preventing unauthorized access, and mitigating fraudulent behavior.

  • System Monitoring: Continuously analyzing application performance and usage patterns to detect potential vulnerabilities or threats.

  • Account Protection: Implementing safeguards to protect user accounts, such as two-factor authentication, encryption, and breach detection protocols.

The legal basis for this processing is our legitimate interest in ensuring the safety and security of our application, systems, and user data. We take proactive measures to safeguard your information and maintain the integrity of our platform.

 

3.9 Insurance and Risk Management

We process personal data to manage insurance policies, assess risks, and ensure robust risk management strategies. This includes:

  • Insurance Claims: Collecting and processing data required for filing, managing, or resolving claims related to our services or operations.

  • Risk Assessment: Evaluating potential risks to our business, assets, and users to inform preventive measures.

  • Consulting Professional Advisors: Sharing relevant data with legal, financial, or insurance advisors to obtain expert guidance and ensure compliance with risk management best practices.

The legal basis for this processing is our legitimate interest in protecting the company, its users, and its assets against unforeseen events and mitigating potential losses or liabilities.

3.10 Legal Claims

In connection with legal proceedings or claims, we may process personal data to protect our legal rights and ensure compliance with legal obligations. This involves:

  • Evidence Collection: Retaining and organizing personal data necessary to support legal actions, defense strategies, or dispute resolution.

  • Compliance with Legal Processes: Responding to subpoenas, court orders, or regulatory inquiries as required by law.

  • Prevention of Abuse: Taking appropriate actions to address misuse of our services, enforce our terms, or resolve conflicts fairly.

The legal basis for this processing is our legitimate interest in safeguarding our legal position, protecting our business, and fulfilling obligations related to regulatory or judicial processes.

3.11 Legal Compliance and Vital Interests

We may process personal data to comply with legal obligations or to protect vital interests in critical situations. These activities include:

  • Regulatory Compliance: Meeting statutory requirements, such as tax reporting, anti-money laundering obligations, or responding to law enforcement requests.

  • Emergency Situations: Using personal data to protect individuals during emergencies, such as natural disasters, health crises, or other situations involving imminent risk to life or safety.

  • Public Health and Safety: Participating in public health initiatives or safety campaigns, when legally mandated or when it serves the greater good.

The legal basis for this processing is our legal obligation to comply with applicable laws and our duty to act in the vital interests of individuals during emergencies. Such actions are carefully assessed to ensure they are proportionate and necessary to meet the situation’s demands.

By elaborating on these purposes and their corresponding legal bases, we reaffirm our commitment to handling personal data responsibly, transparently, and in full compliance with data protection laws. Our goal is to balance our operational needs with your privacy rights, ensuring a secure and trustworthy experience across all interactions.

4. Providing Your Personal Data to Others

4.1 Disclosures to Third Parties
We may disclose your personal data to select third parties to fulfill business functions, comply with legal requirements, and manage risks effectively. These third parties include:

  • Insurers and Risk Management Entities: Data may be shared with insurers for handling claims, managing risk assessments, and fulfilling insurance-related obligations.

  • Professional Advisors: Legal, financial, and other professional consultants may access your data to provide expert advice, support legal compliance, or resolve disputes. Examples include accountants for financial reporting or attorneys for legal matters.

  • Regulatory Bodies: In cases where disclosure is required to meet regulatory standards, data may be shared with relevant authorities.

We ensure that all such disclosures are necessary, proportionate, and compliant with legal and regulatory requirements. Your data is shared only when it supports a legitimate business or legal interest.

4.2 Data Hosting
To ensure the secure and efficient operation of our application, we rely on trusted data hosting providers. Currently, our application’s data is hosted by Amazon Web Services (AWS), a globally recognized cloud service provider. AWS complies with stringent security standards and industry certifications, such as ISO 27001, to protect user data.

The hosting services include:

  • Data Storage: Safeguarding your data in secure data centers equipped with advanced encryption protocols.

  • Data Processing: Handling data processing tasks efficiently to ensure smooth application performance.

These providers are contractually obligated to adhere to our strict privacy and security requirements, ensuring your data is handled responsibly and securely.

4.3 Feedback and Reviews
Your feedback and reviews play a crucial role in improving our services and enhancing user satisfaction. We may share this data with subcontractors or trusted partners for purposes such as:

  • Product Development: Using feedback to guide feature improvements and prioritize updates based on user preferences.

  • Quality Assurance: Sharing reviews with contractors to evaluate and enhance service delivery processes.

  • Marketing and Branding: Highlighting anonymized or aggregate feedback in promotional materials to showcase customer satisfaction.

When sharing your feedback, we take steps to anonymize or aggregate the data wherever possible, ensuring that sensitive or identifying information is not disclosed without your explicit consent.

4.4 Financial Transactions
Financial transactions conducted via our application are securely processed through reputable payment service providers, including PayPal and Stripe. To complete these transactions, we share only the data necessary to facilitate payments, such as:

  • User Identification: Your name, email address, and other identifiers linked to your account.

  • Transaction Information: Details about the transaction, including payment amount, currency, and the services or products purchased.

  • Payment Details: Information required to process payments securely, such as credit card or bank details (processed directly by the payment provider).

Both PayPal and Stripe adhere to the highest industry standards for data security and compliance, including PCI DSS (Payment Card Industry Data Security Standard). You can review their privacy policies for more information:

We ensure all data shared with payment providers is transmitted securely and in strict compliance with applicable regulations.

4.5 Legal Disclosures
In specific circumstances, we may disclose personal data to comply with legal requirements, protect individual safety, or safeguard our legal interests. Such disclosures may occur under the following conditions:

  • Compliance with Legal Obligations: When required by law, such as responding to court orders, subpoenas, or regulatory investigations.

  • Protecting Vital Interests: Sharing data in emergencies to protect lives, health, or safety, such as during natural disasters or urgent medical situations.

  • Legal Proceedings: Using data to support or defend against legal claims, enforce our terms of service, or resolve disputes.

  • Law Enforcement Requests: Cooperating with law enforcement agencies in investigations or actions related to criminal activities or threats to public safety.

We evaluate each legal disclosure request carefully to ensure it is lawful, necessary, and proportional to the circumstances.

By providing these extended details, we ensure transparency and clarity in how we share your personal data with others. Our practices are designed to prioritize your privacy while enabling essential operations, legal compliance, and the continuous improvement of our services.

5. International Policy

5.1 International Data Transfers

As part of providing our services, your personal data may be transferred to, stored, and processed in the United States or other jurisdictions where Brydge Holdings LLC, its affiliates, or its trusted service providers operate. These international transfers are essential for ensuring the functionality, efficiency, and security of our application and related services.

Commitment to Compliance

We recognize the importance of protecting your personal information across borders and are committed to complying with applicable international privacy laws. For users located in Canada and Panama, we have implemented specific measures to ensure that data transfers meet the legal requirements of these jurisdictions:

  • Canada:
    We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy laws, such as those in Quebec, British Columbia, or Alberta. When transferring personal data outside of Canada, we ensure that comparable levels of data protection are maintained through contractual agreements and recognized safeguards.

  • Panama:
    In accordance with Law 81 of 2019 on the Protection of Personal Data, we implement measures to guarantee that personal data transferred internationally is processed in a manner consistent with Panamanian privacy standards. This includes obtaining necessary consents and ensuring proper safeguards are in place.

For other jurisdictions, we strive to align our practices with the requirements of local privacy laws, ensuring that your data is managed responsibly and lawfully.

 

5.2 Safeguards for International Transfers

To protect your personal information during international transfers, we employ rigorous safeguards that ensure your data is handled securely and in compliance with global privacy standards. These include:

  1. Standard Contractual Clauses (SCCs):
    For data transfers to jurisdictions without an adequacy decision, we implement contractual agreements, such as SCCs approved by regulatory authorities, to provide legal protection equivalent to local data protection laws.

  2. Data Protection Certifications:
    We partner with service providers certified under recognized international frameworks, such as the EU-U.S. Data Privacy Framework, where applicable. These certifications demonstrate their compliance with strict data protection standards.

  3. Encryption and Security Protocols:
    All personal data transferred internationally is encrypted during transit and stored using advanced security measures, reducing the risk of unauthorized access or breaches.

  4. Data Minimization:
    We ensure that only the minimum amount of personal data required for specific purposes is transferred, thereby limiting exposure to unnecessary risks.

  5. Ongoing Monitoring:
    We regularly review our data transfer practices and assess the adequacy of safeguards to ensure they remain compliant with evolving regulations and industry standards.

 

5.3 Transparency and Your Rights

We believe in providing complete transparency about where and how your data is processed. As part of this commitment, we:

  • Clearly inform you of any third-party providers involved in data processing and their jurisdictions.

  • Allow you to request additional information about the safeguards applied to your data during international transfers.

  • Provide mechanisms for you to access, modify, or delete your personal data, even when processed internationally.

If you have concerns or questions about international data transfers, you can contact us at any time using the details provided in Section 10 of this Privacy Policy.

 

5.4 Legal Basis for International Transfers

The transfer of personal data to jurisdictions outside your home country is conducted in accordance with applicable legal bases, such as:

  • Your Consent:
    Where required, we obtain your explicit consent before transferring your data internationally.

  • Contractual Necessity:
    Data transfers are often necessary to provide the services you have requested or to fulfill our contractual obligations to you.

  • Legitimate Interests:
    In some cases, international transfers are conducted based on our legitimate interests, such as maintaining operational efficiency, provided that such transfers do not override your privacy rights.

 

5.5 Your Role and Consent

By using our application or services, you acknowledge and consent to the transfer, storage, and processing of your personal data outside your country of residence. You also agree to the application of appropriate safeguards, as outlined above, to protect your data during these transfers.

If you do not wish to consent to international data transfers, certain features of our application may not be available. In such cases, we encourage you to reach out to us to discuss your concerns or explore alternatives.

 

5.6 Commitment to Privacy Across Borders

At Brydge Holdings LLC, we understand the importance of maintaining the privacy and security of your personal data, regardless of where it is processed. Our commitment to compliance with global privacy laws ensures that your data is handled with care, transparency, and integrity at every step.

If you would like further details about our international data transfer practices, or if you wish to exercise your rights, please do not hesitate to contact us. Your privacy and trust remain our highest priorities.

6. Your Rights

We are committed to ensuring that you have full control over your personal data. As a user of our services, you are entitled to several rights under applicable data protection laws. These rights are designed to empower you and provide transparency about how your personal data is used.

6.1 Rights Under Data Protection Laws
Under data protection laws, you have the following rights with respect to your personal data:

  • Access to Your Data:
    You have the right to request access to the personal data we hold about you. This includes information about how your data is being processed, the purposes of processing, and the categories of data involved. We will provide copies of your data upon request in an accessible format.

  • Correction of Inaccurate Data (Rectification):
    If you believe that any of the personal data we hold about you is inaccurate or incomplete, you can request that it be corrected or updated.

  • Deletion of Your Data (Erasure):
    You can request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent (if consent was the legal basis for processing). Please note that this right may be subject to exceptions, such as when we are required by law to retain certain data.

  • Restricting the Processing of Your Data:
    You can ask us to limit the processing of your personal data in specific situations, such as:

    • If you contest the accuracy of the data.

    • When processing is unlawful, you do not wish for the data to be erased.

    • If the data is no longer needed for processing, but you require it to establish, exercise, or defend legal claims.

  • Objection to Data Processing:
    You have the right to object to the processing of your personal data, particularly if the processing is based on our legitimate interests or if your data is being used for direct marketing purposes. Upon receiving your objection, we will assess whether our legitimate interests override your rights and, if not, stop processing your data.

  • Data Portability:
    You may request that we transfer your personal data to another organization or service provider. This applies to data you have provided to us in a structured, commonly used, and machine-readable format, and where the processing is based on consent or a contract.

  • Right to File Complaints:
    If you believe we have violated your rights under data protection laws, you have the right to file a complaint with a relevant data protection authority. We encourage you to contact us first to address your concerns, and we will do our best to resolve the issue promptly.

  • Withdrawal of Consent:
    If your data is processed based on your consent, you have the right to withdraw that consent at any time. Once consent is withdrawn, we will cease processing your personal data for the specific purpose to which consent was provided.

 

6.2 Exercising Your Rights
To exercise any of the rights mentioned above, please contact us using the details provided in Section 9 of this policy. To protect your privacy, we may ask you to verify your identity before fulfilling your request.

Here’s what to expect:

  • Acknowledgment of Your Request:
    Upon receiving your request, we will acknowledge it within a reasonable timeframe, typically within a few business days.

  • Response Time:
    We aim to provide a complete response within one month of receiving your request. If the request is particularly complex or involves a large volume of data, we may extend this period by an additional two months. If an extension is required, we will notify you with an explanation.

  • Data Delivery:
    Where your request involves access or portability, we will provide the data in a commonly used, machine-readable format.

  • Denial of Requests:
    If we are unable to fulfill your request due to legal or operational limitations, we will provide a clear explanation and the reasons for the refusal.

 

6.3 Limitations on Your Rights
While we strive to respect and fulfill your rights, certain limitations and exceptions may apply, including:

  • Legal and Regulatory Obligations:
    We may be required to retain specific personal data to comply with legal or regulatory requirements, such as tax laws, anti-money laundering regulations, or contractual obligations.

  • Public Interest and Research:
    In cases where the processing of personal data is necessary for public interest purposes, scientific or historical research, or statistical analysis, your right to erasure or objection may be limited.

  • Conflicting Rights:
    If fulfilling your request would adversely impact the rights and freedoms of others, such as exposing personal data about another individual, we may be unable to comply fully with your request.

  • Disproportionate Effort:
    In rare cases, if responding to your request would involve excessive or disproportionate effort, we may limit our response. We will, however, make every effort to provide partial responses or explain our reasoning.

 

6.4 Transparency and Assistance
We are committed to ensuring you fully understand your rights and how to exercise them. If you have any questions or require guidance about your rights, you can contact our data protection team. We are here to provide assistance and ensure your privacy is respected at all times.

By maintaining an open and collaborative approach to your data rights, we strive to empower you with full control over your personal information and build a trusted relationship based on transparency and accountability.

 

6.5 Internation Your Rights

Your rights regarding your personal data depend on the privacy laws of your location. We are committed to respecting these rights and ensuring that you have control over how your data is handled. Below is an overview of the specific rights available to users in Canada and Panama:

For Users in Canada (PIPEDA)

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), you are entitled to the following rights:

  • Right to Access: You have the right to access the personal data we hold about you. This includes obtaining a copy of your information and understanding how it is being used.

  • Right to Request Corrections: If you believe your personal data is inaccurate or incomplete, you can request corrections or updates.

  • Right to Withdraw Consent: Where data processing is based on your consent, you have the right to withdraw it at any time. Once consent is withdrawn, we will cease processing your data for the purposes specified.

  • Right to Challenge Compliance: If you believe we are not adhering to PIPEDA, you can challenge our practices by contacting the Office of the Privacy Commissioner of Canada.

For Users in Panama (Law 81 of 2019)

Under Law 81 of 2019 on the Protection of Personal Data, you have the following rights:

  • Right to Access: You can request details about the personal data we have collected about you and how it is being used.

  • Right to Rectification: You may request the correction of any inaccuracies or incomplete information in your personal data.

  • Right to Deletion: You can request the deletion of your personal data, subject to legal and operational obligations that may require its retention.

  • Right to Object: You have the right to object to specific types of data processing, particularly if the processing is not aligned with the purposes for which your data was originally collected.

Right to Information: You are entitled to clear and transparent information about how your personal data is being processed and the purposes for which it is used.

7. Cookies

Cookies play a vital role in enhancing your experience on our application by enabling functionality, personalizing interactions, and providing valuable insights for continuous improvement. Below is an extended overview of our cookie practices.

7.1 What Are Cookies?
Cookies are small data files sent by a web server to your browser and stored on your device. These files typically contain:

  • A Unique Identifier: Used to recognize your device on future visits.

  • Minimal Data: Such as preferences, session details, or tracking information to improve usability.

Cookies enable websites to function efficiently, remember user preferences, and provide tailored services. They are widely used across the internet to support seamless browsing and user-friendly experiences.

7.2 Types of Cookies We Use
Our application utilizes various types of cookies to optimize performance and functionality, as well as to understand user behavior. These include:

  • Essential Cookies:
    These cookies are necessary for the application to function properly. They enable core features such as page navigation, user authentication, and access to secure areas. Without these cookies, the application cannot operate effectively.

  • Session Cookies:
    Session cookies are temporary and only last during your visit to our application. They allow us to remember your actions and preferences during a single session, such as keeping you logged in or retaining items in a shopping cart.

  • Persistent Cookies:
    Persistent cookies remain on your device for a set duration or until deleted manually. These cookies allow us to recognize you on subsequent visits, save your preferences, and create a more personalized experience.

  • Analytics Cookies:
    Analytics cookies collect information about how you interact with our application, such as pages visited, time spent on specific sections, and navigation paths. This data is aggregated and used to improve functionality, monitor performance, and refine user experiences.

  • Advertising and Targeting Cookies:
    These cookies track your browsing habits and interests to deliver relevant advertisements. While we use these cookies to personalize marketing efforts, you can manage or disable them through your preferences.

 

7.3 Connection to Personal Data
While cookies typically do not store personal data such as your name or email address, they may become linked to personal information stored in our application. Examples of this linkage include:

  • Session Identifiers: Cookies storing unique session IDs tied to your account for authentication and security purposes.

  • Preferences: Cookies retaining user-specific settings, such as language selection or interface preferences, associated with your profile.

  • Analytics Integration: Cookies collecting data that, when combined with other information, can help us understand user demographics or behavior.

We handle any personal data linked to cookies in compliance with applicable privacy laws, ensuring it is used responsibly and securely.

 

7.4 Managing Your Cookie Preferences
We provide multiple ways for you to control and manage your cookie preferences to align with your privacy choices. These include:

  • Cookie Banners: On your first visit, you will be presented with a cookie banner offering options to accept, reject, or customize cookies according to your preferences.

  • Browser Settings: Most browsers allow you to manage cookies, including blocking or deleting them entirely. Refer to your browser’s help section for instructions.

  • In-App Settings: Our application includes privacy controls where you can modify your cookie preferences at any time.

By adjusting these settings, you can tailor your cookie usage to suit your comfort level. Note that disabling certain cookies may impact the functionality and usability of the application.

 

7.5 Cookies and Consumer Rights (CCPA/CPRA)
Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), cookies may be classified as "identifiers" or data subject to consumer rights. These rights include:

  • Right to Know: You are entitled to know what cookie-related data is collected and how it is used.

  • Right to opt Out: You can opt out of the sale or sharing of cookie-related data, particularly for advertising purposes.

  • Right to Delete: You can request the deletion of cookie-related data that is linked to your personal information, provided no legal or operational requirements necessitate its retention.

  • Right to Non-Discrimination: Exercising your rights under the CCPA/CPRA will not result in any adverse treatment, such as reduced functionality or limited access to features.

We comply with these requirements by providing transparent cookie practices and ensuring users can easily manage their cookie-related rights.

 

7.6 Transparency and Further Information
Our use of cookies is guided by a commitment to transparency and respect for user privacy. We ensure that:

  • Cookies are used responsibly to improve the user experience and application performance.

  • Data collected through cookies is stored securely and only shared with trusted service providers when necessary.

  • Clear and accessible options are provided to manage your cookie preferences.

For more information about our cookie practices, or if you have questions or concerns, please refer to our Cookie Policy or contact us directly. By maintaining an open and user-centric approach, we aim to ensure that your browsing experience is both enjoyable and secure.

8. Amendments

We are committed to keeping this Privacy Policy up to date to reflect changes in our practices, services, and legal or regulatory obligations. Below is a comprehensive explanation of how and why we may amend this policy and how such updates will be communicated to you.

8.1 Ongoing Policy Updates
We may periodically revise this Privacy Policy to address:

  • Evolving Practices: Updates to our data collection, processing, or sharing methods as new technologies, features, or services are introduced.

  • Legal and Regulatory Compliance: Adjustments to align with changes in data protection laws, regulations, or industry standards.

  • Operational Improvements: Enhancements to our privacy management practices aimed at better protecting your data and improving transparency.

Each update will be reflected in the “Last Updated” date at the top of this policy. We recommend reviewing this Privacy Policy regularly to stay informed about how your personal data is handled. Minor updates that do not materially affect your rights or the processing of your data may not be accompanied by formal notifications but will always be documented on this page.

8.2 Notification of Significant Changes
When we make significant changes to this Privacy Policy, we will ensure you are adequately informed, particularly if these changes impact your rights or involve new ways of processing your personal data. Significant changes may include:

  • New Data Collection Practices: Introducing new categories of personal data or new purposes for processing.

  • Changes to Consent Requirements: Modifications to how we seek, obtain, or rely on your consent for data processing.

  • Legal or Regulatory Mandates: Adjustments driven by new legal obligations or industry requirements that affect how your data is managed.

To notify you of significant changes, we may use one or more of the following methods:

  1. Application Notifications: Displaying an announcement or alert when you next access our application or services.

  2. Direct Communications: Sending an email, SMS, or other direct message to inform you of the changes and provide a link to the updated Privacy Policy.

  3. Updates in Terms of Service: Including references to updated privacy practices in our Terms of Service or other contractual agreements.

Where legally required, we will seek your explicit consent for any changes that involve new data collection, processing, or sharing practices.

8.3 Your Role in Staying Informed
While we strive to notify you of significant updates, we also encourage you to:

  • Regularly Review This Policy: Bookmark this page and check back periodically to stay up to date with the latest version.

  • Contact Us for Clarifications: If you have any questions about changes to this policy, our data practices, or how updates may affect your rights, you can reach out to us at the contact information provided in Section 9.

 

8.4 Your Continued Use of Services
Your continued use of our application or services after updates to this Privacy Policy constitutes your acknowledgment of the changes. If you disagree with any changes, you may opt to discontinue using our services or contact us to discuss your concerns.

9. Our Details

We prioritize transparency and accessibility when it comes to providing information about our organization. Below, you will find detailed contact and ownership information to help you reach us for inquiries, concerns, or assistance regarding our services or this Privacy Policy.

 

9.1 Application Ownership
The Spedy application is fully owned, developed, and managed by Brydge Holdings LLC. As the proprietors, we are responsible for the secure operation of this platform, ensuring compliance with data protection laws and maintaining high standards of user satisfaction.

Brydge Holdings LLC is dedicated to delivering innovative, user-friendly, and privacy-focused solutions. As the operators of Spedy, we take our role as data controllers seriously, ensuring that your personal data is handled responsibly and transparently.

 

9.2 Business Address
Our main office is located at the following address:

Brydge Holdings LLC
14900 Southwest 30th Street, #278552
Miramar, FL 33027
United States

This address serves as our official location for correspondence, including mailed inquiries, legal notices, or requests related to this Privacy Policy. We recommend addressing any postal correspondence to "Privacy Officer" or the relevant department to ensure prompt handling.

 

9.3 Contact Information
We provide multiple channels for communication to ensure your questions or concerns are addressed promptly and effectively. You may reach us through the following methods:

  • By Mail: Send written correspondence to our main office address listed above. For privacy-related matters, please include "Attn: Privacy Officer" in your mailing.

  • By Email:

    • For general inquiries, use the contact email provided on our website.

    • For privacy-related questions, such as data access requests or complaints, please direct your email to the dedicated privacy email address listed on our website under the Privacy Policy section. Clearly state the purpose of your inquiry in the subject line (e.g., "Data Access Request" or "Privacy Complaint").

10. Representatives

We provide dedicated contacts to address data protection inquiries and privacy-related concerns efficiently. Below are the details of our primary representative and Data Protection Officer.

 

10.1 General Data Protection Inquiries
For general inquiries regarding data protection, compliance, or this Privacy Policy, you can reach our representative at:

This contact is available to handle inquiries related to your rights, the processing of your personal data, and other privacy-related matters.

 

10.2 Data Protection Officer (DPO) Contact
If your inquiry requires direct communication with our Data Protection Officer (DPO), such as complex privacy concerns, legal matters, or data access requests, please use the following details:

Our DPO is responsible for overseeing compliance with data protection laws, addressing concerns related to your personal data, and ensuring our practices align with applicable regulations.

11. Data Retention

We understand the importance of retaining personal data responsibly and securely. Our data retention policy is designed to ensure that personal data is stored only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and uphold our contractual commitments. Once the relevant retention periods expire, we take steps to securely delete or anonymize the data to protect your privacy. Below, we provide an extended overview of our data retention practices.

 

11.1 Retention Policy Overview

Our retention practices are guided by the following principles:

  1. Purpose-Driven Retention: Data is retained only for the purposes specified in this Privacy Policy, such as delivering services, improving functionality, ensuring compliance, or supporting business operations.

  2. Legal and Regulatory Compliance: We adhere to all applicable legal and regulatory retention requirements, which may vary by jurisdiction and data type.

  3. Minimization: We retain only the minimum amount of personal data necessary to achieve the specific purposes for which it was collected.

Once data is no longer needed for these purposes, it is securely deleted or anonymized to ensure that it cannot be used to identify individuals.

 

11.2 Retention Periods by Data Type

Retention periods are determined based on the type of data, its purpose, and applicable legal or regulatory requirements:

  • Contact Data:
    Data such as your name, email address, and phone number is retained for as long as necessary to maintain active communication with you. If you request deletion or terminate your relationship with us, this data will be securely removed unless retention is required for legal purposes.

  • Account Data:
    Data related to your user account, including usernames, account settings, and preferences, is retained while your account remains active. If you deactivate or delete your account, this data is removed within a reasonable timeframe unless required for legal or operational reasons.

  • Transaction Data:
    Data related to payments, billing, and financial records is retained for a minimum of seven years or longer, as required by tax, audit, or financial reporting laws in the relevant jurisdictions.

  • Communication Data:
    Records of customer support inquiries, emails, or other communications are retained as necessary to address ongoing issues, maintain service quality, or resolve legal disputes. These records may be retained for longer periods when relevant to legal claims or regulatory investigations.

  • Usage Data:
    Data collected for analytics and service improvement, such as application logs, device information, or usage patterns, is typically anonymized and retained for as long as necessary to enhance performance and user experience. Retention periods for non-anonymized data are limited to operational needs.

 

11.3 Extended Retention Periods

Certain types of data may be retained beyond standard periods under specific circumstances, including:

  1. Legal Compliance:
    Data may be retained to meet legal, regulatory, or contractual obligations, such as responding to law enforcement requests or fulfilling tax and financial reporting requirements.

  2. Fraud Prevention and Security:
    Data required to prevent, detect, or address fraud, security breaches, or other unlawful activities may be retained for extended periods to safeguard our users and systems.

  3. Dispute Resolution:
    If a dispute arises, relevant data may be retained until the matter is resolved or for the duration of applicable statutes of limitation.

  4. Archival Purposes:
    Certain data may be anonymized and archived for historical, research, or statistical purposes, ensuring it no longer identifies individuals.

 

11.4 Deletion and Anonymization Practices

When personal data is no longer required for its original purpose or legal obligations, we take steps to remove it from our systems. These include:

  1. Secure Data Deletion:
    Data is permanently deleted from active databases and backup systems using secure methods that comply with industry standards to prevent unauthorized recovery.

  2. Anonymization:
    Data that is no longer needed for individual identification may be anonymized, rendering it untraceable to any specific individual. Anonymized data may still be used for research, analytics, or service improvement.

  3. User-Initiated Deletion:
    You can request the deletion of your personal data at any time by contacting us (see Section 10). We will assess your request and proceed to delete the data unless retention is required by law or for legitimate business purposes.

 

11.5 Your Role in Data Deletion

We encourage you to take an active role in managing your data. If you wish to delete your account or specific personal data, please contact us with your request. We may require identity verification to ensure the security of your data and prevent unauthorized deletion.

12. Updates to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect updates to our practices, technological advancements, or changes in legal and regulatory requirements. Any updates will be documented with a revised "Last Updated" date at the top of this policy, ensuring transparency and keeping you informed of how your personal data is handled.

12.1 Periodic Updates

Updates to this Privacy Policy may include:

  • Adjustments to our data collection, processing, or sharing practices.

  • Changes required to comply with new or updated legal and regulatory standards.

  • Enhancements to better protect your privacy or improve transparency.

We recommend that you review this Privacy Policy regularly to stay informed about how your personal data is managed.

 

12.2 Notification of Significant Changes

In the event of significant changes that materially affect your rights or the way your personal data is processed, we will notify you through appropriate channels, including:

  • In-App Notifications: A notice or alert will be displayed within the application to inform you of the changes.

  • Direct Communication: We may email you or use other direct communication methods to provide detailed information about the updates.

If necessary, we may also request your explicit consent for changes that involve new or additional data processing activities.

 

12.3 Your Continued Use

By continuing to use our application or services after any updates to this Privacy Policy, you acknowledge and agree to the revised terms. If you do not agree with the changes, you may discontinue using our services or contact us with any concerns.

 

We are committed to maintaining a transparent and user-focused approach to privacy. Should you have any questions or require further information about updates to this Privacy Policy, please contact us using the details provided in Section 10.

Copyright © 2024 Brydge Holdings LLC. All rights reserved.

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