Privacy Policy

Last updated June 13, 2023

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This privacy notice for Spiraf, LLC ("Company,""we," "us," or "our"),describes how and why we might collect, store, use, and/or share ("process")your information when you use our services ("Services"), suchas when you:

• Visit our website at https://spysales.com, or any website of ours that links to     this privacy notice

• Engage with us in other related ways,     including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do notagree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact usat support@spysales.com.

TABLE OF CONTENTS

1. WHAT INFORMATION DOWE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TOPROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOMDO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. WHAT ARE YOURPRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO CALIFORNIA RESIDENTS HAVE SPECIFICPRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DOWE COLLECT?

Personal information youdisclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on theServices, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or other wise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.The personal information we collect may include the following:

• names

• email addresses

• usernames

• passwords

Sensitive Information. We do not process sensitive information.

Payment Data. All payment data is stored by Stripe . You may find their privacy notice link(s) here: https://stripe.com/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your InternetProtocol (IP) address and/or browser and device characteristics — is collectedautomatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of ourServices, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is     service-related, diagnostic, usage, and performance information our     servers automatically collect when you access or use our Services and     which we record in log files. Depending on how you interact with us, this     log data may include your IP address, device information, browser type,     and settings and information about your activity in the Services (such as the date/time stamps associated with your usage,     pages and files viewed, searches, and other actions you take such as which     features you use), device event information (such as system activity,     error reports (sometimes called "crash dumps"), and     hardware settings).

• Device Data. We collect device data such as     information about your computer, phone, tablet, or other device you use to     access the Services. Depending on the device used, this device data may     include information such as your IP address (or proxy server), device and     application identification numbers, location, browser type, hardware     model, Internet service provider and/or mobile carrier, operating system,     and system configuration information.

• Location Data. We collect location data such as     information about your device's location, which can be either precise or     imprecise. How much information we collect depends on the type and     settings of the device you use to access the Services. For example, we may     use GPS and other technologies to collect geolocation data that tells us     your current location (based on your IP address). You can opt out of     allowing us to collect this information either by refusing access to the     information or by disabling your Location setting on your device. However,     if you choose to opt out, you may not be able to use certain aspects of     the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide,improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and     authentication and otherwise manage user accounts. We may process your information so you     can create and log in to your account, as well as keep your account in     working order.

• To save or protect an individual's vital     interest. We may     process your information when necessary to save or protect an individual’s     vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DOWE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information whenwe believe it is necessary and we have a valid legal reason (i.e., legalbasis) to do so under applicable law, like with your consent, to comply withlaws, to provide you with services to enter into or fulfill ourcontractual obligations, to protect your rights, or to fulfill ourlegitimate business interests.

If you are located inthe EU or UK, this section applies to you.

The General Data ProtectionRegulation (GDPR) and UK GDPR require us to explain the valid legal bases werely on in order to process your personal information. As such, we may rely onthe following legal bases to process your personal information:

• Consent. We may process your information if you     have given us permission (i.e., consent) to use your personal     information for a specific purpose. You can withdraw your consent at any     time.

• Legal Obligations. We may process your information     where we believe it is necessary for compliance with our legal     obligations, such as to cooperate with a law enforcement body or     regulatory agency, exercise or defend our legal rights, or disclose your     information as evidence in litigation in which we are involved.
     
     

• Vital Interests. We may process your information     where we believe it is necessary to protect your vital interests or the     vital interests of a third party, such as situations involving potential     threats to the safety of any person.

In legal terms, we aregenerally the "data controller" under European dataprotection laws of the personal information described in this privacy notice,since we determine the means and/or purposes of the data processing we perform.This privacy notice does not apply to the personal information we process as a "dataprocessor" on behalf of our customers. In those situations, thecustomer that we provide services to and with whom we have entered into a dataprocessing agreement is the "data controller" responsiblefor your personal information, and we merely process your information on theirbehalf in accordance with your instructions. If you want to know more about ourcustomers' privacy practices, you should read their privacy policies and directany questions you have to them.

If you are located inCanada, this section applies to you.

We may process yourinformation if you have given us specific permission (i.e., expressconsent) to use your personal information for a specific purpose, or insituations where your permission can be inferred (i.e., implied consent).You can withdraw your consent at any time.

In some exceptionalcases, we may be legally permitted under applicable law to process yourinformation without your consent, including, for example:

• If collection is clearly in the interests     of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection     and prevention

• For business transactions provided     certain conditions are met

• If it is contained in a witness statement     and the collection is necessary to assess, process, or settle an insurance     claim

• For identifying injured, ill, or deceased     persons and communicating with next of kin

• If we have reasonable grounds to believe     an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection     and use with consent would compromise the availability or the accuracy of     the information and the collection is reasonable for purposes related to     investigating a breach of an agreement or a contravention of the laws of     Canada or a province

• If disclosure is required to comply with     a subpoena, warrant, court order, or rules of the court relating to the     production of records

• If it was produced by an individual in     the course of their employment, business, or profession and the collection     is consistent with the purposes for which the information was produced

• If the collection is solely for     journalistic, artistic, or literary purposes

• If the information is publicly available     and is specified by the regulations

4. WHEN AND WITH WHOM DOWE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your     information in connection with, or during negotiations of, any merger,     sale of company assets, financing, or acquisition of all or a portion of     our business to another company.

• Business Partners. We may share your information with     our business partners to offer you certain products, services, or     promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies andsimilar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and howyou can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOURSOCIAL LOGINS?

In Short: If you choose to register or log in to ourServices using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEPYOUR INFORMATION?

In Short: We keep your information for as long asnecessary to fulfill the purposes outlined in this privacy noticeunless otherwise required by law.

We will only keep yourpersonal information for as long as it is necessary for the purposes set out inthis privacy notice, unless a longer retention period is required or permittedby law (such as tax, accounting, or other legal requirements). No purposein this notice will require us keeping your personal information for longerthan six (6) months past the termination of the user's account.

When we have noongoing legitimate business need to process your personal information, we willeither delete or anonymize such information, or, if this is notpossible (for example, because your personal information has been stored inbackup archives), then we will securely store your personal information andisolate it from any further processing until deletion is possible.

8. WHAT ARE YOUR PRIVACYRIGHTS?

In Short: In some regions, such as theEuropean Economic Area (EEA), United Kingdom (UK), and Canada, you have rightsthat allow you greater access to and control over your personalinformation. You may review, change, or terminate your account at anytime.

In some regions(like the EEA, UK, and Canada), you have certain rights under applicabledata protection laws. These may include the right (i) to request access andobtain a copy of your personal information, (ii) to request rectification orerasure; (iii) to restrict the processing of your personal information; and(iv) if applicable, to data portability. In certain circumstances, you may alsohave the right to object to the processing of your personal information. Youcan make such a request by contacting us by using the contact details providedin the section "HOWCAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider andact upon any request in accordance with applicable data protection laws.

If you are located inthe EEA or UK and you believe we are unlawfully processing your personalinformation, you also have the right to complain to your local data protectionsupervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located inSwitzerland, the contact details for the data protection authorities areavailable here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing yourconsent: If we arerelying on your consent to process your personal information, which may beexpress and/or implied consent depending on the applicable law, you havethe right to withdraw your consent at any time. You can withdraw your consentat any time by contacting us by using the contact details provided in thesection "HOW CAN YOU CONTACT USABOUT THIS NOTICE?" below orupdating your preferences.

However, please notethat this will not affect the lawfulness of the processing before itswithdrawal nor, when applicable law allows, will it affect theprocessing of your personal information conducted in reliance on lawfulprocessing grounds other than consent.

Opting out ofmarketing and promotional communications: You can unsubscribe from our marketing andpromotional communications at any time by clicking on the unsubscribe linkin the emails that we send, or by contacting us using the details providedin the section "HOWCAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketinglists. However, we may still communicate with you — for example, to send youservice-related messages that are necessary for the administration and use ofyour account, to respond to service requests, or for other non-marketingpurposes.

Account Information

If you would at anytime like to review or change the information in your account or terminate youraccount, you can:

• Log in to your account settings and     update your user account.

• Contact us using the contact information     provided.

Upon your request toterminate your account, we will deactivate or delete your account andinformation from our active databases. However, we may retain some informationin our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements.

9. CONTROLS FORDO-NOT-TRACK FEATURES

Most web browsers andsome mobile operating systems and mobile applications include a Do-Not-Track("DNT") feature or setting you can activate to signal your privacypreference not to have data about your online browsing activities monitored andcollected. At this stage no uniform technology standardfor recognizing and implementing DNT signals has been finalized.As such, we do not currently respond to DNT browser signals or any othermechanism that automatically communicates your choice not to be tracked online.If a standard for online tracking is adopted that we must follow in the future,we will inform you about that practice in a revised version of this privacynotice.

10. DO CALIFORNIARESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, youare granted specific rights regarding access to your personal information.

California Civil CodeSection 1798.83, also known as the "Shine The Light" law,permits our users who are California residents to request and obtain from us,once a year and free of charge, information about categories of personalinformation (if any) we disclosed to third parties for direct marketingpurposes and the names and addresses of all third parties with which we sharedpersonal information in the immediately preceding calendar year. If you are aCalifornia resident and would like to make such a request, please submit yourrequest in writing to us using the contact information provided below.

If you are under 18years of age, reside in California, and have a registered account withServices, you have the right to request removal of unwanted data that youpublicly post on the Services. To request removal of such data, please contactus using the contact information provided below and include the email addressassociated with your account and a statement that you reside in California. Wewill make sure the data is not publicly displayed on the Services, but pleasebe aware that the data may not be completely or comprehensively removed fromall our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code ofRegulations defines a "resident" as:

(1) every individualwho is in the State of California for other than a temporary or transitorypurpose and

(2) every individualwho is domiciled in the State of California who is outside the State ofCalifornia for a temporary or transitory purpose

All other individualsare defined as "non-residents."

If this definitionof "resident" applies to you, we must adhere to certainrights and obligations regarding your personal information.

What categories ofpersonal information do we collect?

We have collected thefollowing categories of personal information in the past twelve (12) months:

Category

Examples

Collected

A. Identifiers

Contact details,  such as real name, alias, postal address, telephone or mobile contact number,  unique personal identifier, online identifier, Internet Protocol address,  email address, and account name

NO

B. Personal  information categories listed in the California Customer Records statute

Name, contact  information, education, employment, employment history, and financial  information

NO

C. Protected  classification characteristics under California or federal law

Gender and date of  birth

NO

D. Commercial  information

Transaction  information, purchase history, financial details, and payment information

NO

E. Biometric  information

Fingerprints and  voiceprints

NO

F. Internet or other  similar network activity

Browsing history,  search history, online behavior, interest data, and interactions with  our and other websites, applications, systems, and advertisements

NO

G. Geolocation data

Device location

NO

H. Audio,  electronic, visual, thermal, olfactory, or similar information

Images and audio,  video or call recordings created in connection with our business activities

NO

I. Professional or  employment-related information

Business contact  details in order to provide you our Services at a business level or job  title, work history, and professional qualifications if you apply for a job  with us

NO

J. Education  Information

Student records and  directory information

NO

K. Inferences drawn  from other personal information

Inferences drawn  from any of the collected personal information listed above to create a  profile or summary about, for example, an individual’s preferences and  characteristics

NO

We may also collectother personal information outside of these categories through instances whereyou interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer     support channels;

• Participation in customer surveys or     contests; and

• Facilitation in the delivery of our     Services and to respond to your inquiries.

How do we use andshare your personal information?

More information aboutour data collection and sharing practices can be found in this privacy notice.

You may contactus by email at support@spysales.com, by visiting https://spysales.com/contact, or by referring to the contact details at the bottom ofthis document.

If you are usingan authorized agent to exercise your right to opt out we may deny arequest if the authorized agent does not submit proof that they havebeen validly authorized to act on your behalf.

Will your informationbe shared with anyone else?

We may disclose yourpersonal information with our service providers pursuant to a written contractbetween us and each service provider. Each service provider is a for-profitentity that processes the information on our behalf.

We may use yourpersonal information for our own business purposes, such as for undertakinginternal research for technological development and demonstration. This is notconsidered to be "selling" of your personal information.

Spiraf, LLC hasnot disclosed or sold any personal information to third parties for a businessor commercial purpose in the preceding twelve (12) months. Spiraf,LLC will not sell personal information in the future belonging to websitevisitors, users, and other consumers.

Your rights withrespect to your personal data

Right to requestdeletion of the data — Request to delete

You can ask for thedeletion of your personal information. If you ask us to delete your personalinformation, we will respect your request and delete your personal information,subject to certain exceptions provided by law, such as (but not limited to) theexercise by another consumer of his or her right to free speech, our compliancerequirements resulting from a legal obligation, or any processing that may berequired to protect against illegal activities.

Right to be informed —Request to know

Depending on thecircumstances, you have a right to know:

• whether we collect and use your personal     information;

• the categories of personal information     that we collect;

• the purposes for which the collected     personal information is used;

• whether we sell your personal information     to third parties;

• the categories of personal information     that we sold or disclosed for a business purpose;

• the categories of third parties to whom     the personal information was sold or disclosed for a business purpose; and

• the business or commercial purpose for     collecting or selling personal information.

In accordance withapplicable law, we are not obligated to provide or delete consumer informationthat is de-identified in response to a consumer request or to re-identifyindividual data to verify a consumer request.

Right toNon-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will notdiscriminate against you if you exercise your privacy rights.

Verification process

Upon receiving yourrequest, we will need to verify your identity to determine you are the sameperson about whom we have the information in our system. These verificationefforts require us to ask you to provide information so that we can match itwith information you have previously provided us. For instance, depending onthe type of request you submit, we may ask you to provide certain informationso that we can match the information you provide with the information wealready have on file, or we may contact you through a communication method(e.g., phone or email) that you have previously provided to us. We mayalso use other verification methods as the circumstances dictate.

We will only usepersonal information provided in your request to verify your identity orauthority to make the request. To the extent possible, we will avoid requestingadditional information from you for the purposes of verification. However, ifwe cannot verify your identity from the information already maintained by us,we may request that you provide additional information for the purposes ofverifying your identity and for security or fraud-prevention purposes. We willdelete such additionally provided information as soon as we finish verifyingyou.

Other privacy rights

• You may object to the processing of your     personal information.

• You may request correction of your     personal data if it is incorrect or no longer relevant, or ask to restrict     the processing of the information.

• You can designate     an authorized agent to make a request under the CCPA on your     behalf. We may deny a request from an authorized agent that does     not submit proof that they have been validly authorized to act     on your behalf in accordance with the CCPA.

• You may request to opt out from future     selling of your personal information to third parties. Upon receiving an     opt-out request, we will act upon the request as soon as feasibly     possible, but no later than fifteen (15) days from the date of the request     submission.

To exercise theserights, you can contact us by email at support@spysales.com, byvisiting https://spysales.com/contact, or by referring to the contact detailsat the bottom of this document. If you have a complaint about how we handleyour data, we would like to hear from you.

11. DO WE MAKE UPDATESTO THIS NOTICE?

In Short: Yes, we will update this notice as necessaryto stay compliant with relevant laws.

We may update thisprivacy notice from time to time. The updated version will be indicated by anupdated "Revised" date and the updated version will be effectiveas soon as it is accessible. If we make material changes to this privacynotice, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to reviewthis privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@spysales.com or by post to:

Spiraf, LLC

651 N Broad St, Suite201

Middletown, DE 19709

United States