Privacy Policy

Dispel provides a virtual machine provisioning, orchestration, and networking platform via the Dispel website (the “Site”), the Dispel application (the “App”), and related hardware and Internet services (collectively, the “Service(s)”). The Service is operated by Dispel, LLC and its affiliates (the “Company”, “we”, or “us”) for users of the Service (“you” or the “Customer”). This privacy policy describes how we collect, use, and disclose your information when you use our Site, App, Services, and other interactions (e.g., customer service inquiries, user conferences, etc.). Under applicable law, Dispel is the “data controller” of personal data collected through the Services.

At Dispel, we will not:

  • Sell any personal information about our users, other than in connection with a disposition of our company or our assets, as described below; or

  • Turn over any personal information about our users to third party marketing or advertising firms; or

  • Collect any information about your activities for any purpose other than as we have stated in this privacy policy, unless we receive your consent.

What Information We May Collect

When you interact with us through the Services, we may collection information from you, as further described below. We may also receive information about you from other sources, such as public databases, joint marketing partners, social media platforms, and other third parties.

Information You Directly Provide Us

Dispel may collect and receive your data and other information in a variety of ways:

Your Data

You voluntarily provide us with messages, images, files, VoIP and WebRTC data (to enable communication delivery only), or other content you send through the Service (“Customer Data”).

Other Information

Account Information To create or update a Dispel account, you supply us with your first and last name, email address, and password.

Payment Information If you purchase a paid version of the Services, you provide Dispel (or its payment processors) with billing details such as credit card information, banking information, and/or a billing and shipping address. Your credit card information is used solely for billing purposes by our payment provider Stripe. In this instance, under applicable law Stripe is the “data processor.” Your credit card information will be subject to Stripe’s privacy policy rather than our privacy policy. You can learn more about Stripe’s privacy and security practices here.

Information Your Browser Automatically Sends Us

Device Information When you interact with the Services, your browser and devices automatically makes information available to us that we may store. This includes your IP address (which may permit us to estimate your general location), device type, your operating system, and your browser type.

Log Data When you access or use our Services our servers automatically collect information and record it in log files. The log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Services, browser type, settings, date and time the Services were used, language preferences, cookie data, and information about your browser configuration and plugins.

Services Metadata When you interact with the Services, metadata is generated that provides us with information about your activity and usage. For example, Dispel logs the creation of new resources, bandwidth usage, and the parts of our network that you are using. We keep these logs primarily for our internal business operations such as billing, customer service, data analysis, statistical analysis, fraud or other illegal activities monitoring and prevention, enhancing, improving or modifying our products and services, identifying usage trends, and enforcing our Customer and User Terms of Use (collectively “Terms”) and policies.

Analytics Services Provided by Others

We use certain third party services to help us provide, improve and analyze the use of our website, products and services. These companies may collect information about how you use our website, products and services, including unique device identifiers, device manufacturer and operating system, IP address, browser type, pages viewed on the Dispel website, session start/stop time, links clicked on the Dispel website, and conversion information. This information may be used to analyze and track data (including for our billing purposes), determine the popularity of certain content, better understand your online activity, and resolve problems. This enables us to improve and expand upon the services and products that we make available to our users.

A Note on Cookies

We do not use cookies. We use Window.localStorage, which permits us to store certain of your data locally within your browser, rather than in cookies. For security reasons, this data periodically expires, necessitating re-authentication by you.

However, some of our service providers may use cookies and similar technologies to help our users interact with us, as well as for analytical and support purposes (as described above).

Where Information is Processed

The nature of our cloud technology products and services allows users from all over the world but currently, Dispel only operates out of the United States. Therefore, our services and products are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. By using our Services, you consent to the transfer of information to and from the United States and other countries outside of your country of residence, which may have different data protection rules than those of your country. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

Our Use of Your Information

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem.

We may use the collected information for:

  • To respond to your questions and fulfill your requests.

  • To send helpful information to you, such as notifying you of changes to our terms of use, end user license agreement or privacy policy.

  • To complete and fulfill your purchases and provide you with customer service.

  • To send you marketing communications (which you can opt out of- see Choice and Access below).

  • To personalize your experience on our website and use of our products and services.

  • To allow you to participate in our promotions, which may have their own rules.

  • For our other internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our products and services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process, litigation and/or requests from the U.S. or a state Government; (c) to enforce our Terms and EULA; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

  • To comply with our internal policies or legal proceedings in connection with investigations of any violations or suspected violations of our Terms and/or EULA; we reserve the right to use, release or otherwise share any usage logs or other records concerning you if you violate the Terms or EULA, or intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity.

If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Dispel may use it for any business purpose. To the extent information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Information.”

Our Legal Basis for Handling Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

  • To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.

  • Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: This includes:

    • Providing a safe and enjoyable user experience;

    • Customer service;

    • Marketing, e.g. sending emails or other communications to let you know about new features;

    • Protecting our users, personnel, and property;

    • Analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features;

    • Processing job applications;

    • Processing billing;

    • Managing legal issues.

  • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

  • To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent medical situation.

  • Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.

Our Disclosure of Your Information

Dispel uses Customer Data and Other Information in furtherance of our legitimate interests in operating our Services. Dispel may provide information:

  • With your consent.

  • To related companies such as subsidiaries, parents, and affiliates for purposes consistent with this Privacy Policy.

  • To our third party service providers who provide services such as website hosting, data analysis, payment processing, IT and related infrastructure provision, email delivery, mailing, auditing and other similar services.

  • To identify you to anyone to whom you send a message or refer through the use of our website, products or services.

  • To a buyer or other acquiring entity in the event of acquisition, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process, litigation and/or requests from the U.S. or a state Government; (c) to enforce our Terms and EULA; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

  • To comply with our internal policies or legal proceedings in connection with investigations of any violations or suspected violations of our Terms and/or EULA; we reserve the right to use, release or otherwise share any usage logs or other records concerning you if you violate the Terms or EULA, or intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity.

Third Party Services

This privacy policy does not apply to the privacy, information or other practices of any third parties, including any third party operating any site or service to which there is a link on our website or through our products or services. The inclusion of a link on our website or through our products or services does not imply an endorsement by us or by our affiliates of the linked site or service.

Data Retention

Dispel will retain Customer Data in accordance with a Customer’s instructions. You may be able to customize the retention policies for your Customer Data. The deletion of some Customer Data may cause the deletion of some Other Information.

Dispel may retain Other Information for so long as it may be relevant to the purposes identified herein. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Dispel to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

To dispose of data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time, although we will delete your Personal Information from backups as soon as practically possible.

Security

Dispel takes the security of your data very seriously. We take steps to protect Customer Data and Other Information within our organization using reasonable measures. These steps take into account the sensitivity of the Customer Data and Other Information we collect, process and store, and the current state of technology. Given the nature of technology and the Internet, Dispel cannot guarantee that all data transmissions or storage systems are completely secure from intrusions.

If you have any concerns regarding security, please immediately reach out to us at legal@dispel.io.

Your Data Rights And Choices

You have choices regarding our use and disclosure of your Personal Information.

Individuals in certain countries, including the European Economic Area, have certain legal rights to request access to Information, as well as to seek to update, delete or correct this Information. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways.

The rights and options described below are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

For your protection, when you are exercising your data protection rights we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request to ensure we are making the changes to the proper account.

How do I change email marketing settings?

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please keep in mind that if you opt-out, we will still send you important administrative messages such as billing and legal notices, from which you cannot opt-out.

How can I access the Personal Information you have about me?

If you would like to submit a data access request, you can do so by contact legal@dispel.io with the words “Personal Data Access Request” in the subject or body of the message. We will then start the process and provide you a link to access the personal data that Dispel has on you within 30 days.

How do I correct, update, amend, or delete the personal data you have about me?

If you would like to review, correct, update, suppress, or delete the personal information that you have provided to us, you may contact us at legal@dispel.io with the words “Personal Data Request” in the subject or body of the message.

In your request, please make clear what personal information you would like to have changed, whether you would like to have it suppressed from our database or otherwise let us know what limitations you would like to put on our use of it.

How do I object or restrict the manner in which Dispel processes my personal data?

You have a right to ask us to stop using or limit our use of your personal data in certain circumstances—for example, if we have no lawful basis to keep using your data, or if you think your personal data is inaccurate. Please contact us at legal@dispel.io to do so.

Use of the Service by Minors

To the extent prohibited by applicable law, Dispel does not allow use of our Services and websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.

Changes to this Privacy Policy

We may update this privacy policy from time to time, and we will notify you of any such updates by either updating the “Last Updated” legend on this page; sending you some form of communication; or posting a notice on our website when the privacy policy has been updated. Please review the latest privacy policy periodically, especially before providing us with any information. Your continued use of our website, products and services means that you have accepted our latest privacy policy.

Contacting Us

If you have any questions about this privacy policy, please do not hesitate to contact us at legal@dispel.io. Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us. If you would like to send us a secure message, please ask for our public key and contact us at secure@dispel.io.