PRIVACY POLICY

Effective Date: July 24, 2020

This Privacy Policy describes information SpiralKore (“SpiralKore” or “we”) may collect when you visit or interact with any website powered by SpiralKore (collectively, the “Websites”; individually, the “Site”) or a direct inquiry to SpiralKore through electronic means. This Privacy Policy discloses how SpiralKore stores, uses, discloses, or shares that information. 

Please read this Privacy Policy carefully. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE WEBSITES. By accessing or using the Websites, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Websites after the Privacy Policy is modified is deemed to be acceptance of those modifications. 

This Privacy Policy does not apply to information collected by third parties, including via websites that may be accessible from or linked to this Site. SPIRALKORE IS NOT RESPONSIBLE FOR THE CONTENT OR PRIVACY PRACTICES OF ANY NON-SPIRALKORE WEBSITE TO WHICH THE WEBSITES LINK. 

1. Scope. 
1. Use of Site. This Privacy Policy applies to information collected when you use the Site, and in electronic communications transmitted through the Site. It does not apply to information collected offline. In addition, this Privacy Policy does not apply to information collected by any third parties, whether or not the Site includes links to the websites of those third parties.  
2. Purpose of the Site. SpiralKore provides information on its products and services. 
2. Information We Collect. SpiralKore collects personal information and non-personal information. 
1. “Non-personal Information” is any information that does not identify you individually or does not permit a direct association with an individual. Non-personal Information may include information derived from Personal Information that has been de-personalized by removing unique identifiers and/or combining it with information about other users to form aggregated data. 
2. “Personal Information” is information that is reasonably capable of being associated or could be linked, directly or indirectly, with a particular consumer or household. SpiralKore collects some information that is about you individually, but does not identify you, and collects information about your internet connection, your device used to access the Site, and your use of the Site. If SpiralKore combines that information with personal information, it will treat it as personal information.
3. Examples of information SpiralKore collects include:
1. Registration information you provide when you create an account or sign up for information, including your name, date of birth, mailing address, phone number, email address, username, and password;
2. Transaction information you provide when you make a purchase, such as your postal address, telephone number, and payment information;
3. Information we obtain from a third party, such as a third-party site, vendor, service provider, or other platform provider;
4. Location information, including location information provided by a mobile device or other device as you navigate our Site;
5. Activity information about your use of the Site;
6. Usage, viewing, technical, and device data when you visit the Site or interact with communications from our Site. 
3. How We Collect. SpiralKore collects information from and about you directly when you provide such information to SpiralKore and automatically when you use the Site.  
1. Information You Provide. SpiralKore collects information you provide when you make inquiries using the “contact us” form or complete a transaction. The information collected may include anything submitted by you to the Site and may include copies of the correspondence.  When you purchase goods or services through the Site, you voluntarily provide certain Personal Information, which may be processed by a third-party website, and SpiralKore receives the information provided through that third party website. If you voluntarily provide your Personal Information to us, we collect it. You choose whether to disclose Personal Information, but you may not be able to use the Site or conduct certain transactions without doing so. 
2. Information Collected Automatically. When you visit or otherwise use the Site, SpiralKore collects details about your access and use of the Site automatically through cookies, SpiralKore, web beacons, and other similar technology, including details about your device, internet connection, operating system, browser type, browsing actions, and the resources that you access and use on the Site, other traffic data, and, location data. The information SpiralKore collects automatically may include personal information or SpiralKore may associate it with personal information it collects in other ways or receives from third parties. If SpiralKore associates such data with personal information, SpiralKore will treat it as personal information, but if such data is not associated with other personal information, SpiralKore will treat it as non-personal information. 
4. Cookies and Related Technology. SpiralKore may use the following technologies to collect data as you visit the Site. 
1. “Cookies” are small pieces of information that are stored by your internet browser on your device. Cookies can be either persistent or temporary. A persistent cookie retains user preferences for a particular website, allowing those preferences to be used in future sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). Temporary cookies expire at the end of a user session when the browser is closed. SpiralKore may set its own cookies or may ask others to set them to help SpiralKore. Most internet browsers are initially set to accept cookies. You can set your browser to refuse cookies, but then you may not be able to access or use portions of this Site. 
2. “Web beacons” and “Pixels” are small bits of code embedded in web pages or emails that assist in delivering cookies and measuring statistics. Web beacons and SpiralKore help SpiralKore determine whether a page on this Site has been viewed and, if so, how many times. SpiralKore may also use web beacons and SpiralKore in email messages to determine what the recipient has done with the message. Although you cannot decline to receive web beacons and SpiralKore when visiting a web page, you can choose not to receive them by email if you disable HTML images or refuse HTML email messages.  
5. How We Use. SpiralKore uses information that you provide and/or that SpiralKore collects to present the Site to you, improve the Site, deliver a more personalized service to you, to provide you with information, products, and/or services that you request from SpiralKore, to market SpiralKore’s goods and services to you, to fulfill any other purpose for which you provide such information, to provide you with other information you requested, in any other way SpiralKore may describe when you provide the information, and for any other purpose with your consent. The way SpiralKore uses such information is described in more detail in the chart below. SpiralKore may aggregate the information you provide or that SpiralKore collects from you with information collected from other users to allow SpiralKore to evaluate its products and services. SpiralKore may use the information it collects to contact you about SpiralKore’ products and services that may interest you; and, if required by law, we will obtain your approval to do so. If you do not want SpiralKore to use your information this way, please see Section 7 below. 

1. To Whom We Disclose. 
1. General. SpiralKore may disclose aggregated information about its users and information that does not identify any individual without restriction. SpiralKore may disclose personal information that it collects or you provide as described in this Privacy Policy, to SpiralKore’s business partners, affiliates, contractors, distributors, or service providers, and other third parties SpiralKore uses to support its business; to a purchaser or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SpiralKore’s assets; to fulfill the purpose for which you provided the personal information; for any other purpose when you consent to such disclosure at the time you provide the information. SpiralKore may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, to enforce SpiralKore’ terms of use and other agreements, and if SpiralKore believes disclosure is necessary or appropriate to protect the rights, property, or safety of SpiralKore, its customers, or others. 
2. Google Analytics and Google Analytics Advertising. The Site uses Google Analytics. Google Analytics assists SpiralKore with collecting and monitoring data about traffic to the Site. Google Analytics collects visitation information via Google advertising cookies and identifiers. You can learn how Google collects and processes data by visiting the following website: www.google.com/policies/privacy/partners/. If you would like to opt-out of the collection of data by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.  For information about how to opt out of Google Marketing Platform’s use of cookies, visit https://optout.networkadvertising.org/?c=1.  For more information about targeting and advertising cookies and how to opt out of those, visit optout.aboutads.info. This Site also uses Google Analytics Advertising, including Google Demographics and Interest Reporting, Google Display and Search Remarketing, and Google Display Impression Reporting. Google Analytics Remarketing uses cookies to track users who visit the Site and display ads when users are on other websites. If you would like opt-out of the Google Analytics Advertising Features, you can adjust your Ad Settings and Ad Settings for mobile apps. For information on how to adjust your Ad Settings, visit the following website: https://support.google.com/accounts/answer/2662856?co=GENIE.Platform%3DAndroid&hl=en. For more information about Google Analytics’ currently available opt-outs, visit the following website: https://tools.google.com/dlpage/gaoptout/. 
3. Third Party Analytics. SpiralKore also engages Facebook and may engage other third-party service providers to assist with collecting and monitoring data about traffic to the Site, as well as to display ads to users when users are on other websites. These third parties use cookies, web beacons, pixels, and other tracking technologies to collect or receive information from SpiralKore, the Site, or elsewhere on the internet, as discussed in Section 4 above, and will use that information to provide measurement services and targeted advertisements. You have the ability to opt-out of the collection or use of your data for remarketing, retargeting, online behavioral advertising, and interest-based advertising. You may do so by visiting the following websites: www.networkadvertising.org/choices, www.aboutads.info/choices, or http://www.youronlinechoices.eu/.
2. Your Choices. You have some choices about how personal information you provide to us or that we collect is used. 
1. Do Not Track. The Site does not respond to web browser Do Not Track (“DNT”) signals. 
2. Tracking Technologies. You may set your browser to refuse some or all browser cookies, or to alert you when cookies are being sent. To learn how to manage or delete cookies on your browser, visit the browser developer’s website. To learn how to manage Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that parts of the Site may not be accessible or may not function properly. 
3. Updating Information. You may contact SpiralKore at the contact information set forth below to request access to, correct, or delete certain personal information that you have provided to SpiralKore. SpiralKore may not accommodate a request to change information if SpiralKore believes the change would violate any law or legal requirement or cause the information to be incorrect.  
3. Data Transfer. SpiralKore stores your personal information in the United States. The privacy protections in the United States may not be the same as in your home country. If you are located in a country outside the United States and submit personal information to SpiralKore, you consent to the general use and disclosure of such information as provided in this Privacy Policy and to the transfer and/or storage of that information to the United States.
4. Data Retention and Security. 
1. Data Retention. SpiralKore may store your personal information as long as you use SpiralKore’s services and/or purchase SpiralKore’s goods in order to provide you with such goods and services and for a legitimate business purposes. SpiralKore may store your personal information to the extent required to comply with SpiralKore’s legal, accounting, and/or reporting requirements and to provide information about SpiralKore’s products or services that you may request. Additionally, SpiralKore may continue to store your personal information contained in standard backups. Upon your request, SpiralKore will delete or de-identify your personal information unless SpiralKore is legally required or permitted to maintain such personal information. 
2. Data Security. SpiralKore has implemented some measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. SpiralKore cannot guarantee the security of your personal information transmitted to or through the Site. Any transmission of personal information is at your own risk. SpiralKore is not responsible for circumvention of any privacy settings or security measures contained in the Site. 
5. Changes to Privacy Policy. Changes to the Privacy Policy will be posted on this page. If SpiralKore makes material changes to the way it treats users’ personal information, SpiralKore may choose to notify you by email or through a notice in addition to posting. The date the Privacy Policy was last revised appears at the top of the Privacy Policy. You are responsible for ensuring SpiralKore has a current email address for you and for periodically visiting the Site and the Privacy Policy to check for any changes.
6. Children. The Site is not for children. SpiralKore does not knowingly collect personal information from children under the age of 18 through the Site. If SpiralKore learns that it has collected or received such information, it will delete that information. If you believe we might have information from or about a child under the age of 18, please let us know by contacting us using the information set forth in Section 15. 
7. Nevada Residents.  Under Nevada law, Nevada residents may submit a request directing SpiralKore not to make certain disclosures of personal information We maintain about them. If you are a Nevada resident and wish to exercise this right, you may contact us by email at __________________ or by phone at ____________.
8. Links. This Site contains link to third party websites that SpiralKore does not control. SpiralKore cannot be held responsible for third parties’ privacy practices or content provided on such websites. If you click on one of these links, please understand that you are leaving the SpiralKore Site and any information you provide will not be covered by this Privacy Policy. Please read that website’s privacy policy before providing any information. 
9. Contact Information. If you have any questions or comments about this Privacy Policy and SpiralKore’ privacy practices, please contact SpiralKore at: 

SpiralKore

Phone: 859-699-1815

Email: [email protected]

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

Last Updated: July 24, 2020

Last Reviewed: July 24, 2020

This Supplemental Privacy Notice for California Residents (this “Supplemental Notice”) supplements SpiralKore’ Privacy Policy and applies to you if you reside in California. This Supplemental Notice is adopted to comply with the California Consumer Privacy Act of 2018 (the “CCPA”). It also addresses requirements of certain other California laws. Capitalized terms used without definition shall have the meanings ascribed to them in the Privacy Policy and other undefined terms shall have the meanings ascribed to them in the CCPA. 

1. Information We Collect. The Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to a consumer or personal device. For purposes of this Supplemental Notice, such information constitutes personal information. 
1. Personal Information Collected. Below are categories of personal information recognized by the CCPA (“Personal Information”), along with examples (provided by the CCPA) of types of personal information in each category. Please note that the below examples are provided by the CCPA; SpiralKore does not necessarily collect all information listed:

•  Identifiers. Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers
•  CA Customer Records Statute categories. Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
•  Protected Class Characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
•  Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
•  Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
•  Internet/network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement
•  Geolocation data. Physical location or movements
•  Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information
•  Professional/employment-related information. Current or past job history or performance evaluations
•  Non-public education information. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
•  Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

1. Exclusions. Personal Information does not include publicly available information from government records, deidentified or aggregated consumer information, and information excluded from the CCPA’s scope (such has HIPAA–protected information and information protected by the Gramm-Leach Bliley Act). Personal Information collected as part of a communication or transaction between SPIRALKORE and a representative of a government agency or other business, where the transaction is made for providing or receiving a good or service to or from such government agency or other business or conducting due diligence in connection with the foregoing is also excluded from the scope of this Supplemental Notice except with respect to Section 4(c) (non-discrimination).
2. Sources. We obtain Personal Information from you, including from you directly when you provide SpiralKore with the information, from you indirectly when you interact with the Site, and from you when you make electronic communications to SpiralKore. 

1. Use of Personal Information. SpiralKore uses the Personal Information it collects in the ways described in Section 5 of the Privacy Policy. SpiralKore may use the Personal Information for commercial purposes as well as business purposes. 
2. Disclosure of Personal Information. 
1. Disclosure. SpiralKore uses the Personal Information it collects in the ways described in Section 6 of the Privacy Policy. SpiralKore has shared or disclosed Personal Information within the past twelve months as described below.  The following chart identifies the categories of Personal Information recognized by the CCPA and collected by SpiralKore, provides examples of the types of Personal Information within each category collected by SpiralKore, indicates whether SpiralKore has collected such categories of Personal Information during the past twelve months, the source of such Personal Information, how SpiralKore uses such Personal Information, and to whom SpiralKore has disclosed such Personal Information within the past twelve months: 

1. Sale. SpiralKore does not sell Personal Information. 

1. California Rights. The CCPA provides you with specific rights as a California resident. This section identifies those rights and how to exercise them. 
1. Access and Data Portability. Subject to certain exceptions, you have the right to request certain information about SpiralKore’ collection, use, and/or disclosure of your personal information over the past 12 months. After receipt of a verifiable consumer request from you, SpiralKore will disclose to you the categories of personal information collected, categories of sources for the categories of personal information collected, business or commercial purpose for collecting such personal information, categories of third parties with whom SpiralKore shared such personal information, and specific pieces of personal information collected about you. 
2. Deletion. Subject to certain exceptions necessary to the functionality of the Websites, you may request that SpiralKore delete Personal Information about you that it has collected and retained.  
3. Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under the CCPA. 
4. Opt-Out. SpiralKore does not sell Personal Information. 
2. California Request Process. 
1. Instructions. If you reside in California, only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. Such a request must provide sufficient information to allow SpiralKore to reasonably verify that you are (or are an authorized representative of) the person about whom SpiralKore collected the Personal Information, and describe your request with sufficient detail to allow SpiralKore to properly understand, evaluate, and respond to it.  Please note that SpiralKore cannot respond to your request or provide you with information if SpiralKore cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with SpiralKore. SpiralKore will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. If you reside in California, you may exercise your Personal Information rights by submitting verifiable consumer requests in one or more of the following manners:
1. You may make verifiable requests to exercise your Personal Information rights via the online request portal.
2. If you prefer to submit your verifiable request to exercise your Personal Information rights by phone, you may contact SpiralKore by phone toll free at 877.508.8850 or by submitting a request using any of the contact information set forth in Section 8 below. 
2. Verifying Requests. SpiralKore will confirm receipt of your request within the time period prescribed by the CCPA and/or its regulations, let you know how SpiralKore will process the request, and let you know SpiralKore’s verification process and anticipated timeframe for response. SpiralKore may try to verify your request by asking you to provide certain information and matching it to the information SpiralKore maintains about you. SpiralKore will request at least two data points about you. Depending on the nature of your request, SpiralKore may require more data points to match and/or may require you to sign a declaration confirming under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. 
3. Authorized Agent. If you are a California resident, you may designate an authorized agent to make requests on your behalf to exercise your Personal Information rights. The authorized agent must be registered with California’s Secretary of State. The authorized agent making any request on your behalf to know or delete certain Personal Information about you must submit a copy of the written permission you granted them to act as authorized agent or a copy of the document showing you granted them a power of attorney for this purpose. If the authorized agent does not have a power of attorney in compliance with California’s probate law, you must also directly verify your identity with SpiralKore. If adequate proof is not presented, SpiralKore may deny the request. 
4. Response Timing and Format. SpiralKore will try to respond to a verified consumer request within forty five (45) days of receipt, but if SpiralKore requires more time to respond, it will let you know how long and why in writing. SpiralKore will respond to you by mail or electronically at your option. Any disclosures SpiralKore provides in response to your request will pertain only to the 12-month period immediately preceding receipt of the verifiable consumer request. If SpiralKore is unable to respond to the request, SpiralKore will explain why, if applicable. If SpiralKore is unable to verify your identity in connection with a request for specific pieces of information about you, SpiralKore will let you know (but will not disclose the specific pieces of information) and will evaluate the request as though it were a request for categories of Personal Information disclosed to third parties during the past 12 months. If SpiralKore denies a request due to conflict with federal or state law or an exception to the CCPA, SpiralKore will explain the basis for the denial. If SpiralKore cannot verify your identity in connection with a request to disclose categories of information disclosed to third parties, SpiralKore will let you know and will provide you information about its general business practices regarding collection, maintenance, and sale of Personal Information (as described herein). If SpiralKore cannot verify the identity of an individual requesting deletion of Personal Information, SpiralKore will deny your request. SpiralKore has no obligation to provide you with specific Personal Information if such disclosure creates a substantial, articulable, and unreasonable risk to security. For any data portability requests, SpiralKore will provide your Personal Information in the following format: by pdf. Unless your request is excessive, repetitive, or manifestly unfounded, SpiralKore will not charge a fee to process or respond to your request. If SpiralKore determines that a fee is warranted, SpiralKore will explain why it reached that decision and provide you with a cost estimate before responding. 
3. Changes to Privacy Policy. Changes to the Supplemental Notice will be posted on this page. If SpiralKore makes material changes to the way it treats users’ Personal Information, it may choose to notify you by email or through a notice in addition to posting. The date the Supplemental Notice was last revised appears at the top of the Supplemental Notice. You are responsible for ensuring that SpiralKore has a current email address for you and for periodically visiting the Site and the Supplemental Notice to check for any changes.
4. Third Party Marketing. California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact SpiralKore at the contact information set forth in Section 8 below. 
5. Contact. If you have any questions or comments about this Supplemental Notice and SpiralKore’ privacy practices, or if you wish to exercise your rights as a California resident, please contact SpiralKore at: 

SpiralKore

Email: [email protected]