Privacy Policy

1. Introduction

Spencer ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our executive compensation intelligence platform and related services (the "Service").

By accessing or using the Service, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Information We Collect

We collect information that you provide directly to us, information we collect automatically when you use the Service, and information from third-party sources.

Information You Provide

• •Account Information: Name, email address, company name, job title, and password when you create an account
• •Payment Information: Billing address and payment details processed through our secure payment provider
• •User Content: Queries, peer groups, saved searches, and any data you upload or create within the Service
• •Communications: Information you provide when contacting us for support or feedback

Information Collected Automatically

• •Usage Data: Features accessed, queries made, reports generated, and time spent on the Service
• •Device Information: Browser type, operating system, device identifiers, and IP address
• •Cookies and Tracking: We use cookies and similar technologies to maintain sessions and improve the Service

3. How We Use Your Information

We use the information we collect to:

• •Provide, maintain, and improve the Service
• •Process transactions and send related information
• •Send technical notices, updates, security alerts, and support messages
• •Respond to your comments, questions, and customer service requests
• •Monitor and analyze trends, usage, and activities to improve user experience
• •Detect, investigate, and prevent fraudulent transactions and other illegal activities
• •Personalize and improve your experience with the Service

4. AI and Data Processing

Spencer uses artificial intelligence to analyze SEC filings and provide executive compensation insights. When you use our AI features:

• •Your queries are processed by our AI systems to generate responses and analysis
• •We may use third-party AI providers (such as Anthropic) to process certain requests
• •We do not use your queries or data to train AI models without your explicit consent
• •SEC filings analyzed by the Service are publicly available documents

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• •Service Providers: With vendors and service providers who perform services on our behalf, such as payment processing, data hosting, and customer support
• •Legal Compliance: When required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Spencer, our users, or others
• •Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets
• •With Your Consent: In any other circumstances where you have given your consent

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• •Encryption of data in transit and at rest
• •Secure authentication through industry-standard providers
• •Regular security assessments and monitoring
• •Limited access to personal information on a need-to-know basis

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with the Service. We may also retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.

When you delete your account, we will delete or anonymize your personal information within 90 days, unless retention is required for legal or legitimate business purposes.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

• •Access: Request access to your personal information we hold
• •Correction: Request correction of inaccurate personal information
• •Deletion: Request deletion of your personal information
• •Portability: Request a copy of your personal information in a portable format
• •Opt-out: Opt out of marketing communications at any time

To exercise any of these rights, please contact us at chase@spencertool.ai. We will respond to your request within a reasonable timeframe.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and track information about your use of the Service. Cookies are small data files stored on your device that help us improve the Service and your experience.

Types of cookies we use:

• •Essential Cookies: Required for the Service to function properly
• •Analytical Cookies: Help us understand how users interact with the Service
• •Functional Cookies: Remember your preferences and settings

You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Service.

10. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• •The right to know what personal information we collect, use, and disclose
• •The right to delete your personal information
• •The right to opt out of the sale of personal information (we do not sell personal information)
• •The right to non-discrimination for exercising your privacy rights

11. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We take appropriate safeguards to require that your personal information remains protected in accordance with this Privacy Policy.

12. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by posting a notice on the Service prior to the changes becoming effective. We encourage you to review this Privacy Policy periodically for the latest information on our privacy practices.

14. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: