Types of Information
We may collect the following types of Information through our Platform:
(1) “Personal Data” such as your name, e-mail address, physical address, phone number, credit card number, specific (e.g. street level) geolocation data and other information that can be used to directly identify you (which, in some cases, may include certain Device Information such as device identifiers);
(2) “Device Information” which is information relating to the computer or device you are using when you access our Platform, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings;
(3) “Usage Data” which is data related to your use of the Platform such as the pages you visit, the sites you use before or after visiting ours, your actions within the Platform, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, WiFi connections, general geolocation information, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Platform through automated means such as cookies.Personal Data
You may access some features of our Platform without submitting any Personal Data. However, there are certain offerings within our Platform which will require you to give us Personal Data so that we can provide you with certain services, including if you choose to:
Please note that your credit card information will only be collected if you choose to make a purchase through our Platform. If you do make such a purchase, our payment processing partner will collect your payment information and process your payment. We do not store any credit card information or share it with anyone other than our payment processor.
Device Information & Usage Data
Whether or not you submit Personal Data, any time you visit our Platform, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and also in aggregate form for internal business purposes, such as optimizing the Platform, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.
In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes without first giving you the ability to opt in or opt out of such disclosure. We only share your Information with third parties for the purposes described below.
We may share your Personal Data with third party sponsors or partners who will use it for marketing purposes but only if you opt in to such sharing or do not opt out when prompted. We will never share Personal Data in this manner without giving you one of these two options.
We contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including payment processing, e-mail and hosting services, software development, shipping and fulfillment, data management, surveys and marketing, and administration of promotions. We call them our “Service Providers.” We may share your Personal Data and other Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Personal Data only for such purposes.
We may also share, make available or transfer Device Information and Usage Data in anonymized form with or to our affiliates, licensees, promotional partners and Service Providers for administrative, analytical, research, optimization, promotional and security purposes, but no such Information will be linked with your Personal Data or be used to identify you.
Notwithstanding any of the above, we will not share your Personal Data if such sharing is prohibited by applicable privacy and data protection law.
We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Platform, customizing the content offered to you on the Platform and delivering relevant advertising to you.
By visiting the Platform, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Platform through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.
You can opt out of the collection and use of certain information, which we collect about you by automated means, by changing the settings in the device you use to access the Platform. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Platform.
When you access the Platform through a mobile device, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience and the content you receive. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time thereafter by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application, which will also cause you to lose the applicable feature for which such location data was collected.
It is entirely your choice whether or not you provide Personal Data to us. We take reasonable precautions to protect our customers' Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at firstname.lastname@example.org
Our Platform or communications may contain links to third party websites over which we exercise no control, including the form of advertising, embedded content, sponsored content or co-branded content. Except as set forth in this Policy, we do not share your Personal Data with those third parties and are not responsible for the privacy policies of any third party or their management of your Personal Data. Because they may treat your Information differently than we do, we recommend that you read the privacy policies on those third-party websites prior to submitting any Personal Data.
As described above, we may use the Personal Data we collect from you to send you newsletters, push notifications, general communications and promotional e-mails, including promotional communications about our Platform and our or our partners’ products or services. If you do not want to receive such communications, you can opt out by using the unsubscribe link at the bottom of our communications, unchecking the applicable box to opt out when prompted, or by simply not opting in when prompted. You may also at any time opt out of receiving communications from us by sending an e-mail to email@example.com with the subject line “Opt Out.”
We will access and share your Personal Information or any of the information within the accessed activities if we have a good faith belief that: (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms and Conditions for the Platform, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Platform, or (iv) such action is appropriate to protect the rights, property or safety of Spirtu, its employees, users of the Spirtu Service, or others.
Under certain laws, you may have the right to: obtain confirmation that we hold Personal Data about you, request access to and receive information about the Personal Data we maintain about you, receive copies of the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, object to the continued processing of your Personal Data, and have the Personal Data blocked, anonymized or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law. If you qualify, in order to exercise these rights, please contact our legal representative as set forth below.
MORTON & ASSOCIATES LLP
246 West Broadway
New York, NY 10013
We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
Please understand, however, that we reserve the right to retain an archive of such Personal Data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.
All data generated by website and application are stored on servers located in the United States, State of New York. If you believe your personality rights are infringed upon through content in this website or application, please contact firstname.lastname@example.org to file a removal request. Your email must contain the words 'removal request' in the subject line, and include (a) your identity and why you believe you are authorized making such request, (b) specifics about the particular content (if video with exact description of the time code and duration of the infringement), (c) a return address if you communicate throgh means other than electronic mail. If you send your request in form of physical correspondence, it must include your signature. While not mandatory, we encourage you to include a telephone number (and indicate what time for calls are suitable) so questions can be clarified more easily.
If you are a visitor of the Platform and a resident of California, and you wish to view, update, delete, or transfer your personal information and/or otherwise exercise your rights pursuant to the California Consumer Privacy Act, please email email@example.com
For any questions, please contact our legal representatives:
Morton & Associates LLLP
246 West Broadway
New York NY 10013