Privacy policy

Steerpath Oy (“Steerpath”, Spacehub “we”, “us”, or “our”) is focused onmaking the Spacehub service the safest and best possible experience foryou and our/your end-users (“you”, “your”). We have great respect forpeople’s personal privacy, and we consider this a matter of greatimportance. In order to provide you with a useful service when you arepurchasing our products or using our services; we need some data fromyou in order to do so; otherwise we cannot provide you with a usefulproduct and service. Our commitment to you is that we will use our bestefforts 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”) andsets forth the collection, use, and disclosure practices that apply to theSpacehub Website, Spacehub service, Steerpath Services, and SteerpathProducts (herein “Services”). By purchasing or using the Experience; youexplicitly accept, without limitation or qualification; the collection, use, anddisclosure of personal information provided by you in the mannerdescribed in this Policy. Please read the Policy carefully as it affects yourrights and liabilities. If you disagree with the way we collect and processpersonal information, please do not use the Steerpath “Spacehub”Experience.

1.What Information Do We Collect?

Information You Submit

When you request information, subscribe to or order a product, service oremail marketing register as a user, respond to an online survey, orotherwise actively send us data; we may collect data including, but notlimited to; your name, email address(es), mailing address(es), telephonenumber(s), (location information) and information related to the businessyou represent. If the product or service provided is something we chargefor, we will also collect payment information; such as credit card numbersand related verification information, phone number, email address, andbilling / shipping addresses; in order to process the order.In all of the above cases, you will know exactly what data we collectthrough the Site, because you actively submit it to us.

Information We Gather

As part of the standard operation of the Site, we may collect informationfrom your computer or device; including but not limited to your browsertype, device type, operating system, IP address,the domain name fromwhich you accessed the Site and data associated with customerrelationship management and/or marketing. Additionally, we may collectbehavioral information about your use of the Site; this includes but is notlimited to; the date and time you visit the Site, actions taken while viewinginformation 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 youreturn to the Site, and other such analytics data. We may also collectsimilar data regarding your usage of our Services. We also may acquirepersonal 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 becollected by a Steerpath “Spacehub” customer or other affiliated thirdparty; and this information may be stored, transmitted, processed, orotherwise put into some form of use; using some or all elements ofSteerpath Services “Spacehub” or resources (such as servers anddatabases etc.). The collection and usage of such information occursoutside the control of Steerpath, and therefore we are not responsible forany privacy issues caused by a Steerpath “Spacehub” customer orotherwise affiliated third party. The third party in question is responsiblefor upholding and enforcing their own Privacy Policies, LicenseAgreements, and Terms of Service. Please review our Terms of Use formore information.

2. How Do We Use the Information?

For the purposes of this policy, the terms “using” and “processing” ofinformation includes; the use of cookies, analyzing information throughvarious methods, other means of storage on a computer or mobiledevice, and also the collecting, storing, evaluating, modifying, deleting,using, combining, disclosing and transferring information; within ourorganization or among our subsidiaries within the European Union, theUnited States, or internationally.

Personal Information

We use Personal Information for only the following purposes: (1) tooperate the Services, (2) account verification, (3) to fulfill product andservices requests, (4) to improve and optimize the Services, (5) topersonalize your experience, (6) responding to inquiries or providingsupport, (7) to provide software updates and product announcements, (8)to better understand your needs and interests, (9) for marketing purposesand (10) to provide you with further information and offers from us thatwe believe you may find useful or interesting, such as targetedadvertising or promotional campaigns.

Non-Personally Identifiable Information

We may use Non-Personally Identifiable Information for the followingpurposes: (1) to analyze trends and usage of resources throughaggregated data, (2) to improve the features and functionality of ourServices, (3) to better understand your needs and interests, and (4) tobetter understand the needs and interests of End-Users. We may alsoshare Non-Personally Identifiable Information from End-Users with ourSteerpath Account Holders, to allow them to provide more value to endusers,or to provide more insight into end-users. In this context, anyinformation shared with Account Holders; will not contain or be linked toyour Personal Information; unless you have given us your explicit consentor the end-user has given us their explicit consent. For example, aSteerpath “Spacehub” Account Holder may want to better understandhow to create a compelling and non-intrusive experience for end-users,and Steerpath “Spacehub” may provide aggregated information to showexamples of practices that worked well, and practices that did not workwell.


We may send You marketing regarding Spacehub Service as well as aboutproducts and services offered by third parties. The marketing can be sentboth by e-mail, push notifications and in-app. The purpose to sendmarketing is to inform You about Our Services and relevant offers fromthird-parties. We may also process personal data for the purpose ofevaluating a marketing campaign which may include that We will transfersome personal data, mainly e-mail addresses, to the relevant marketingcampaign partners.The lawful basis for sending marketing regarding Our Services and those ofthird parties is your consent (Art. 6 (1) sentence 1 point (a) GDPR), which Youmay withdraw at any time. Where we process personal data for evaluatingmarketing 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 theactual 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 yourcomputer or device when you access the Site. We may use cookiesand/or other storage on your device to help us collect, maintain, and usethis information, for the following purposes: (1) personalize yourexperience and provide you with customized content, (2) monitor Site andAccount usage to better understand how you interact with our Services,(3) remember you when you return to the Site, and (4) conduct researchto 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 yousome form of ability to manage your cookie preferences.We may also use a third party analytics partner, who may employ someform of software technology to help us better manage content on ourSite; by informing us about what content is effective. The informationgathered by third party analytics software is not tied to PersonallyIdentifiable Information; however the use of cookies and othertechnologies by our partners and service providers is not covered by ourprivacy statement. We do not have access or control over these thirdparty 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 IPaddress and page visits; and may set a cookie to enable their feature tofunction properly. Social media features are either hosted by a third partyor hosted directly on our Site. Your interactions with these features aregoverned by the privacy policy of the company providing it.


You can delete existing cookies and prevent the use of cookies in browsersettings. Instructions are available at However,disabling cookies may prevent the proper functionality of the website.Youcan use the Your Online Choices service to control how your data iscollected 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 serviceproviders and suppliers, if such disclosure enables any of them toperform a business, professional, or technical support function for us, forexample to process payments, (2) as necessary if we believe that therehas been a policy violation such as those published on our site, or someviolation of terms you signed, or some other violation of our rights or therights of any third party, (3) to respond to judicial process and provideinformation to law enforcement agencies, or in connection with aninvestigation on matters related to public safety, as permitted by orotherwise required by law, and (4) otherwise with your consent.Additionally in the event of a merger, acquisition, reorganization, or saleof our company or our assets, or in the event of our bankruptcy; yourpersonal information may be one of the transferred or acquired assets.We may also share your personal information where you have grantedus permission to do so, and we reserve the right to use and disclose anyinformation collected via the Site that is not in a Personally Identifiableform.

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

You may review, update, correct, or delete any Personal Information inyour Steerpath “Spacehub” Account by contacting us, or by making theappropriate modifications in your Account profile or preferences. If youcompletely delete all such information, then your account may becomedeactivated. If you would like us to delete your Account and/or removeyour records from our system, please contact us and we will delete youraccount within 30 days if we do not have any legal obligation to retainthe record.

5. Is My Information Secure?

Security is of paramount importance to us, and we work hard to ensurethat our Site and Services are as secure as possible. We have takencertain physical, electronic, contractual, and managerial steps tosafeguard and secure the information we collect from Site visitors andService users. However no method of transmission over the Internet, ormethod of electronic storage, is ever 100% secure; therefore while weendeavor to use commercially acceptable means to protect yourpersonal information, we cannot guarantee its absolute security. If youregister on our Site or use our Services, it is your responsibility to protectthe security of your Account, and any end-users you are providingservices 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 governmentaljurisdiction where the privacy laws may not be as protective as those inyour jurisdiction. We have taken reasonable measures to ensurecompliance with the privacy laws of the United States of America and theEuropean Union, and will take further reasonable measures to maintainand/or improve compliance in the future. The protections given to you bythis Privacy Policy still apply. Your submission of any such informationdiscussed 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 ThirdParties may use our Services to provide services to end-users. ThirdParties may have privacy policies that differ from our own, and we arenot responsible for the activities and practices that take place on thesesites; or any services provided through our Services. We thereforeencourage you to review the privacy policy posted on the Third PartyWebsite; should you access them through the Site, or through ourServices. The fact that we may link to or incorporate a third party’sservices, functionality, or website; or present some type of advertisement;is not an endorsement, authorization, or representation of our affiliationwith that third party; nor is it an endorsement of their privacy orinformation security policies or practices. We do not exercise control overThird Party Websites, or any third party services provided through ourServices; including their use of personal information. Our Privacy Policyonly applies to our Site and Services, and we are not responsible for theprivacy practices or content of other websites, or third party servicesprovided 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 asis needed to provide you with our Services. We will retain and use yourinformation as necessary to comply with our legal obligations, resolvedisputes, and enforce our agreements. Additionally we will deleteinformation 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 currentPrivacy Policy and Terms of Service to which this Privacy Policy isincorporated.

Changes to This Policy

We reserve the right to make changes to this privacy policy from time totime at our sole discretion. When we do, we will post the change(s) on ourwebsite.

You may contact Us at: