Steerpath Oy (“Steerpath”, Spacehub “we”, “us”, or “our”) is focused on

making the Spacehub service the safest and best possible experience for

you and our/your end-users (“you”, “your”). We have great respect for

people’s personal privacy, and we consider this a matter of great

importance. In order to provide you with a useful service when you are

purchasing our products or using our services; we need some data from

you in order to do so; otherwise we cannot provide you with a useful

product and service. Our commitment to you is that we will use our best

efforts to ensure any information submitted to, or gathered by us;

remains private, and is only used for the purposes set forth in this policy.

This page states the Spacehub Privacy Policy (herein the “Policy”) and

sets forth the collection, use, and disclosure practices that apply to the

Spacehub Website, Spacehub service, Steerpath Services, and Steerpath

Products (herein “Services”). By purchasing or using the Experience; you

explicitly accept, without limitation or qualification; the collection, use, and

disclosure of personal information provided by you in the manner

described in this Policy. Please read the Policy carefully as it affects your

rights and liabilities. If you disagree with the way we collect and process

personal information, please do not use the Steerpath “Spacehub”


1.What Information Do We Collect?

Information You Submit

When you request information, subscribe to or order a product, service or

email marketing register as a user, respond to an online survey, or

otherwise actively send us data; we may collect data including, but not

limited to; your name, email address(es), mailing address(es), telephone

number(s), (location information) and information related to the business

you represent. If the product or service provided is something we charge

for, we will also collect payment information; such as credit card numbers

and related verification information, phone number, email address, and

billing / shipping addresses; in order to process the order.

In all of the above cases, you will know exactly what data we collect

through the Site, because you actively submit it to us.

Information We Gather

As part of the standard operation of the Site, we may collect information

from your computer or device; including but not limited to your browser

type, device type, operating system, IP address,the domain name from

which you accessed the Site and data associated with customer

relationship management and/or marketing. Additionally, we may collect

behavioral information about your use of the Site; this includes but is not

limited to; the date and time you visit the Site, actions taken while viewing

information on the Site, which areas or pages of the Site you visit or view,

the amount of time you spend viewing the Site, the number of times you

return to the Site, and other such analytics data. We may also collect

similar data regarding your usage of our Services. We also may acquire

personal information from third parties who provide it to us.

Information Obtained Through Other Sources

Due to the nature of our Services, information about you may be

collected by a Steerpath “Spacehub” customer or other affiliated third

party; and this information may be stored, transmitted, processed, or

otherwise put into some form of use; using some or all elements of

Steerpath Services “Spacehub” or resources (such as servers and

databases etc.). The collection and usage of such information occurs

outside the control of Steerpath, and therefore we are not responsible for

any privacy issues caused by a Steerpath “Spacehub” customer or

otherwise affiliated third party. The third party in question is responsible

for upholding and enforcing their own Privacy Policies, License

Agreements, and Terms of Service. Please review our Terms of Use for

more information.

2. How Do We Use the Information?

For the purposes of this policy, the terms “using” and “processing” of

information includes; the use of cookies, analyzing information through

various methods, other means of storage on a computer or mobile

device, and also the collecting, storing, evaluating, modifying, deleting,

using, combining, disclosing and transferring information; within our

organization or among our subsidiaries within the European Union, the

United States, or internationally.

Personal Information

We use Personal Information for only the following purposes: (1) to

operate the Services, (2) account verification, (3) to fulfill product and

services requests, (4) to improve and optimize the Services, (5) to

personalize your experience, (6) responding to inquiries or providing

support, (7) to provide software updates and product announcements, (8)

to better understand your needs and interests, (9) for marketing purposes

and (10) to provide you with further information and offers from us that

we believe you may find useful or interesting, such as targeted

advertising or promotional campaigns.

Non-Personally Identifiable Information

We may use Non-Personally Identifiable Information for the following

purposes: (1) to analyze trends and usage of resources through

aggregated data, (2) to improve the features and functionality of our

Services, (3) to better understand your needs and interests, and (4) to

better understand the needs and interests of End-Users. We may also

share Non-Personally Identifiable Information from End-Users with our

Steerpath Account Holders, to allow them to provide more value to endusers,

or to provide more insight into end-users. In this context, any

information shared with Account Holders; will not contain or be linked to

your Personal Information; unless you have given us your explicit consent

or the end-user has given us their explicit consent. For example, a

Steerpath “Spacehub” Account Holder may want to better understand

how to create a compelling and non-intrusive experience for end-users,

and Steerpath “Spacehub” may provide aggregated information to show

examples of practices that worked well, and practices that did not work



We may send You marketing regarding Spacehub Service as well as about

products and services offered by third parties. The marketing can be sent

both by e-mail, push notifications and in-app. The purpose to send

marketing is to inform You about Our Services and relevant offers from

third-parties. We may also process personal data for the purpose of

evaluating a marketing campaign which may include that We will transfer

some personal data, mainly e-mail addresses, to the relevant marketing

campaign partners.

The lawful basis for sending marketing regarding Our Services and those of

third parties is your consent (Art. 6 (1) sentence 1 point (a) GDPR), which You

may withdraw at any time. Where we process personal data for evaluating

marketing campaigns the relevant lawful basis is Our legitimate interests

(Article 6(1)(f), GDPR) to analyze the result of Our marketing campaigns.

You may always opt out from Our marketing efforts, either directly in the

actual marketing message or by contacting Us at

Cookies and Other Technologies

A cookie is a small text file that may be stored on the hard drive of your

computer or device when you access the Site. We may use cookies

and/or other storage on your device to help us collect, maintain, and use

this information, for the following purposes: (1) personalize your

experience and provide you with customized content, (2) monitor Site and

Account usage to better understand how you interact with our Services,

(3) remember you when you return to the Site, and (4) conduct research

to improve our content and services.You may refuse to accept cookies,

but by doing so you may not be able to use certain features on the Site,

or take full advantage of all of our offerings. All web browsers offer you

some form of ability to manage your cookie preferences.

We may also use a third party analytics partner, who may employ some

form of software technology to help us better manage content on our

Site; by informing us about what content is effective. The information

gathered by third party analytics software is not tied to Personally

Identifiable Information; however the use of cookies and other

technologies by our partners and service providers is not covered by our

privacy statement. We do not have access or control over these third

party cookies and technologies.

Our Site also includes social media features, such as the Facebook “Like”

button and Instagram “like” button. These features may collect your IP

address and page visits; and may set a cookie to enable their feature to

function properly. Social media features are either hosted by a third party

or hosted directly on our Site. Your interactions with these features are

governed by the privacy policy of the company providing it.


You can delete existing cookies and prevent the use of cookies in browser

settings. Instructions are available at However,

disabling cookies may prevent the proper functionality of the website.You

can use the Your Online Choices service to control how your data is

collected and used in several different services

3. When Do We Share or Disclose Information?

We may disclose or share information collected from you and about you;

to the following entities; for the following purposes: (1) to our service

providers and suppliers, if such disclosure enables any of them to

perform a business, professional, or technical support function for us, for

example to process payments, (2) as necessary if we believe that there

has been a policy violation such as those published on our site, or some

violation of terms you signed, or some other violation of our rights or the

rights of any third party, (3) to respond to judicial process and provide

information to law enforcement agencies, or in connection with an

investigation on matters related to public safety, as permitted by or

otherwise required by law, and (4) otherwise with your consent.

Additionally in the event of a merger, acquisition, reorganization, or sale

of our company or our assets, or in the event of our bankruptcy; your

personal information may be one of the transferred or acquired assets.

We may also share your personal information where you have granted

us permission to do so, and we reserve the right to use and disclose any

information collected via the Site that is not in a Personally Identifiable


4. How Can I Update or Delete My Personal Information?

You may review, update, correct, or delete any Personal Information in

your Steerpath “Spacehub” Account by contacting us, or by making the

appropriate modifications in your Account profile or preferences. If you

completely delete all such information, then your account may become

deactivated. If you would like us to delete your Account and/or remove

your records from our system, please contact us and we will delete your

account within 30 days if we do not have any legal obligation to retain

the record.

5. Is My Information Secure?

Security is of paramount importance to us, and we work hard to ensure

that our Site and Services are as secure as possible. We have taken

certain physical, electronic, contractual, and managerial steps to

safeguard and secure the information we collect from Site visitors and

Service users. However no method of transmission over the Internet, or

method of electronic storage, is ever 100% secure; therefore while we

endeavor to use commercially acceptable means to protect your

personal information, we cannot guarantee its absolute security. If you

register on our Site or use our Services, it is your responsibility to protect

the security of your Account, and any end-users you are providing

services to through our Services and your Account.

International Transfer

Your information may be transferred to, maintained on, and processed;

on computers located outside of your country, or other governmental

jurisdiction where the privacy laws may not be as protective as those in

your jurisdiction. We have taken reasonable measures to ensure

compliance with the privacy laws of the United States of America and the

European Union, and will take further reasonable measures to maintain

and/or improve compliance in the future. The protections given to you by

this Privacy Policy still apply. Your submission of any such information

discussed in this policy, represents your agreement to that transfer.

Links, and Third Party Sites and Services

The Site may contain links to Third Party Websites, and some Third

Parties may use our Services to provide services to end-users. Third

Parties may have privacy policies that differ from our own, and we are

not responsible for the activities and practices that take place on these

sites; or any services provided through our Services. We therefore

encourage you to review the privacy policy posted on the Third Party

Website; should you access them through the Site, or through our

Services. The fact that we may link to or incorporate a third party’s

services, functionality, or website; or present some type of advertisement;

is not an endorsement, authorization, or representation of our affiliation

with that third party; nor is it an endorsement of their privacy or

information security policies or practices. We do not exercise control over

Third Party Websites, or any third party services provided through our

Services; including their use of personal information. Our Privacy Policy

only applies to our Site and Services, and we are not responsible for the

privacy practices or content of other websites, or third party services

provided through our Services.

6. General

Do Not Track

We do not currently use a mechanism to act upon “Do Not Track”

instructions. We are however investigating such mechanisms.

Information Retention

We will retain your information for as long as your Account is active, or as

is needed to provide you with our Services. We will retain and use your

information as necessary to comply with our legal obligations, resolve

disputes, and enforce our agreements. Additionally we will delete

information after it is no longer useful for providing our Services.

Children’s Information

The Site and our Services are not directed to children under the age of 13,

nor do we knowingly collect any personal information from them.

Policy Agreement

By using any part of the Site or our Services, you agree to the current

Privacy Policy and Terms of Service to which this Privacy Policy is


Changes to This Policy

We reserve the right to make changes to this privacy policy from time to

time at our sole discretion. When we do, we will post the change(s) on our


You may contact Us at: