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Privacy Policy

Effective Date: January, 2024

At SPIRL, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of SPIRL's Services is at all times subject to our Terms and Conditions, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

If you have a disability, you may access this Privacy Policy in an alternative format by contacting support@spirl.com.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

2.1. Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data:

Profile or Contact Data
  • First and last name
  • Email
  • Phone number
  • Mailing address
  • Service Providers
  • Analytics Partners
  • Advertising Partners 

Device/IP Data
  • IP address
  • Type of device/operating system/browser used to access the Services
  • Service Providers
  • Analytics Partners
  • Advertising Partners 

Web Analytics
  • Web page interactions (including with ads)
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Advertising Partners
  • Analytics Partners

Professional or Employment-Related Data
  • Resume
  • Job title
  • Job history 

 

Geolocation Data
  • IP-address-based location information
  • Service Providers
  • Analytics Partners
  • Advertising Partners

Other Identifying Information that You Voluntarily Choose to Provide
  • Identifying information in emails or letters you send us
  • Analytics Partners
  • Advertising Partners

2.2. Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You 

  • When you provide such information directly to us. 
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically. 
  • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
  • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties 

  • Vendors 
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners 
  • We receive information about you from some of our vendors who assist us with marketing or promotional services for the Services related to how you interact with our websites, applications, products, Services, advertisements or communications.

2.3. Our Commercial or Business Purposes for Collecting Personal Data

  • Providing, Customizing and Improving the Services 
    • Creating and managing your account or other user profiles
    • Providing you with the Services, or other products, services or information you request
    • Meeting or fulfilling the reason you provided the information to us, such as to message to your friend inviting him or her to sign-up for the Service
    • Providing support and assistance for the Services
    • Analyzing trends and consumers’ interactions with the Services
    • Improving the Services, including testing, research, internal analytics and product development
    • Personalizing the Services, website content and communications based on your preferences
    • Doing fraud protection, security and debugging
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act  as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Virginia Consumer Data Protection Act (the “VCDPA”), the Colorado Privacy Act (the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), or Utah Consumer Privacy Act (the “UCPA”) (collectively, the “State Privacy Laws”).
  • Marketing the Services 
    • Marketing and selling the Services
    • Providing you with customized offers or promotions that we think might be interested to you
    • Showing you advertisements, including interest-based or online behavioral advertising, and retargeted online and mobile advertisements to you across computers or devices you may use
  • Corresponding with You 
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Company or the Services
    • Sending emails and other communications according to your preferences or that display content that we think will interest you
  • Meeting Legal Requirements and Enforcing Legal Terms 
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities
    • Protecting the rights, property or safety of you, SPIRL or another party
    • Enforcing any agreements with you
    • Responding to claims that any posting or other content violates third-party rights
    • Resolving disputes

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include: 
    • Hosting, technology and communication providers, such as AWS
    • Analytics providers, such as Google Analytics and Facebook Pixel
  • Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include: 
    • Ad Networks
    • Marketing providers

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

3.2. Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

3.3. Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. 

We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. 
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region)
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/. 
  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” 

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

4.1. Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

4.2. Opt-out Choices

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices or www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, see http://www.aboutads.info/appchoices.

We provide our consumers with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications, you may use one of these convenient methods:

  • Electronic Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may click the unsubscribe link in the footer of any email, or contact us at support@spirl.com with “Unsubscribe Promotional Offers” in the subject line.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties (including without limitation our third party service providers or partners) with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@spirl.com.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@spirl.com.

7.1. Access

You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:

  • The categories of Personal Data that we have collected about you
  • The categories of sources from which that Personal Data was collected
  • The business or commercial purpose for collecting or selling your Personal Data
  • The categories of third parties with whom we have shared your Personal Data
  • The specific pieces of Personal Data that we have collected about you

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort. 

7.2. Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effect. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

7.3. Correction 

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

7.4. Personal Data Sales and Shares Opt-Out

In this section, we use the term ‘sell’ and ‘share’ as it is defined in the CCPA. We sell and/or share your Personal Data, subject to your right to opt-out as described in this section.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered “selling” or “sharing” of information. You can opt out of these sales by following the instructions in this section.

We sell or share your Personal Data to the following categories of third parties:

  • Analytics providers, such as Google Analytics and Facebook Pixel
  • Marketing providers
  • Ad Networks

Over the past 12 months, we have sold the following categories of your Personal Data to categories of third parties listed above:

  • Profile or Contact Data
  • Device/IP Data
  • Web Analytics
  • Geolocation Data
  • Other Identifying Information that You Voluntarily Choose to Provide

We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:

  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sale of your Personal Data by following the instructions in the “Exercising Your Rights under State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

To our knowledge, we do not sell the Personal Data of minors under 16 years of age.

7.5 Limit the Use of Sensitive Personal Information

 Consumers have the right to request that we limit the use or sharing disclosure of their Sensitive Personal Information (“Right to Limit”). However, since our use and disclosure of Sensitive Information are limited to the purposes set forth in section 7027(m) of the CCPA regulations, including: 1) performing the services or providing the goods reasonably expected, 2) preventing, detecting, and investigating security incidents, 3) resisting malicious, deceptive, fraudulent, or illegal actions, 4) ensuring physical safety of natural persons, 5) for short-term transient use, 6) performing services on behalf of the business, 7) verifying or maintaining quality or safety of a product or service, and 8) collecting or processing Sensitive Personal Information but not for the purpose of inferring characteristics, we do not offer a way for you to submit such a request.] 

7.6. We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Colorado Resident Rights

If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@spirl.com.

8.1 Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.

8.2 Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

8.2 Deletion

You have the right to delete Personal Data concerning you. 

8.3 Personal Data Sales and Targeted Advertising Opt-Out

In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales. 

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.

We sell and process for the purposes of targeted advertising your Personal Data to the following categories of third parties:

  • Analytics providers, such as Google Analytics and Facebook Pixel
  • Marketing providers

We sell and process for the purposes of targeted advertising the following categories of your Personal Data to categories of third parties listed above:

  • Profile or Contact Data
  • Commercial Data
  • Device/IP Data
  • Web Analytics
  • Social Network Data
  • Consumer Demographic Data
  • Geolocation Data
  • Internet or other similar network activity information
  • Other Identifying Information that You Voluntarily Choose to Provide

We have sold the foregoing categories of Personal Data for the following business or commercial purposes:

  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights” section. If you are under 13 years of age, your parent or guardian must authorize us to sell or process for the purposes of targeted advertising your Personal Data.

8.4 Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the CPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that Produce Legal or Similarly Significant Effects Concerning a Consumer,’ as defined in the CPA that concern you.

8.5 We Will Not Discriminate Against You

We will not process your personal data in violation of state and federal laws that prohibit unlawful discrimination against consumers. 

Connecticut Resident Rights

If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights under State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Connecticut resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@spirl.com.

9.1 Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

9.2 Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

9.3 Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

9.4 Portability

You have the right to request a copy of your Personal Data that is processed automatically in a machine-readable format, to the extent technically feasible. 

9.5 Personal Data Sales and Targeted Advertising Opt-Out

In this section, we use the term ‘sell’ as it is defined in the CTDPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales. 

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CTDPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section. You can opt out from these “sales” by following the instructions in the “Exercising Your Rights under State Privacy Laws” section. 

Under the CTDPA, we disclose the Personal Data of minors under 13 years of age in a way that may be considered a sale, including processing for the purposes of targeted advertising. If you are under 13 years of age, your parent or guardian must authorize us to sell or process for the purposes of targeted advertising your Personal Data.

9.6 Profiling 

We do not process your Personal Data for ‘Profiling’ as defined under the CTDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

9.7 We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA

We will not discriminate against you for exercising your rights under the CTDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CTDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CTDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Utah Resident Rights

If you are a Utah resident, you have the rights set forth under the Utah Consumer Privacy Act (“UCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Utah resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@spirl.com.

10.1 Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

10.2 Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

10.3 Deletion

You have the right to delete Personal Data that you have provided to us. 

10.4 Opt-Out of Certain Processing Activities

  • You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We process your Personal Data for targeted advertising purposes. You can opt out this processing of your Personal Data by following the instructions under the “Exercising Your Rights under the State Privacy Laws” Section. 
  • You have the right to opt-out to the sale of your Personal Data. UCPA defines sale as the exchange of Personal Data for monetary consideration to a third party. You can opt out this processing of your Personal Data by following the instructions under the “Exercising Your Rights under the State Privacy Laws” Section. 

10.5 We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA

We will not discriminate against you for exercising your rights under the UCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the UCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the UCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@spirl.com.

11.1 Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

11.2 Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

11.3 Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

11.4 Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

11.5 Opt-Out of Certain Processing Activities

  • You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes.  We process your Personal Data for targeted advertising purposes. 
  • You have the right to opt-out to the sale of your Personal Data. VCDPA defines sale as the exchange of Personal Data for monetary consideration to a third party.  

To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section. 

11.6 We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA

We will not discriminate against you for exercising your rights under the VCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the VCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the VCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights under State Privacy Laws

To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado or Connecticut resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

If you are a California, Colorado, Connecticut, Virginia, or Utah resident, you may opt-out from any “sales,” “shares,” or targeted advertising, by using the following methods:

  • Install the Google Analytics Opt-out Browser Addon found here:  https://tools.google.com/dlpage/gaoptout/.
  • Email us at support@spirl.com
  • By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does include Do Not Track signals.

If you are a California resident, you may exercise your Right to Limit by using the following methods:

If you are a Colorado resident, you may opt out from the processing of your Sensitive Data (or Sensitive Data Inferences) by using the following methods:

If you are a Colorado Resident and have previously consented to a secondary use of processing your Personal Data you, revoke your consent by using the following methods:

You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:

If you are a California, Colorado or Connecticut resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

12.1 Appealing a Denial

If you are a Colorado, Connecticut, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the CPA, CTDPA, or VCDPA (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods: 

  • Email us at: support@spirl.com (title must include “[STATE OF RESIDENCE] Appeal”)
  • Mail us at: 555 Bryant St Ste 877, Palo Alto, CA 94301


If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: www.oag.state.va.us/consumer-protection/index.php/file-a-complaint (VA), www.coag.gov/resources/colorado-privacy-act/ (CO), and www.portal.ct.gov/AG/Sections/Privacy/The-Privacy-and-Data-Security-Department (CT).

Other State Law Privacy Rights

13.1. California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@spirl.com.

13.2. Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@spirl.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.  

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.  Company will be the controller of your Personal Data processed in connection with the Services. 

What Personal Data Do We Collect From You? We collect Personal Data about you as set forth in the “Categories of Sources of Personal Data” section above.

How Do We Use Your Personal Data?  We may use any Personal Data that we collect with third parties in conjunction with any of the activities described under “How We Disclose Your Personal Data” and “Our Commercial or Business Purposes for Collecting Personal Data” sections above.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services.  When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. 
  • Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.  

Examples of these legitimate interests include:

    • Operation and improvement of our business, products and services
    • Marketing of our products and services 
    • Provision of customer support
    • Protection from fraud or security threats
    • Compliance with legal obligations
    • Completion of corporate transactions 
  • Consent:   In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.  When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
  • Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?  We share Personal Data as described in “How We Disclose Your Personal Data” section above. 

How Long Do We Retain Your Personal Data?  We retain Personal Data about you as described in “Data Security and Retention” section above.

What Security Measures Do We Use?  We seek to protect Personal Data as described in “Data Security and Retention” section above.

What Rights Do You Have Regarding Your Personal Data?  You have certain rights with respect to your Personal Data, including those set forth below.  For more information about these rights, or to submit a request, please email support@spirl.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision.  In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

  • Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.  
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. 
  • Portability:  You can ask for a copy of your Personal Data in a machine-readable format.  You can also request that we transmit the data to another controller where technically feasible. 
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes. 
  • Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint:  You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. 

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the SPIRL website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

https://spirl.com
support@spirl.com
555 Bryant St Ste 877, Palo Alto CA 94301