Privacy Policies

 Privacy Statement

Last Modified: 6/20/2024

Introduction

The following Privacy Policy (the “Policy”) describes how Spiron Solutions LLC (“Operator”) collects, uses, and shares personally identifiable information and non-personally identifiable information collected (collectively referred to as “Data”) through website, mobile website, mobile applications, and social media platforms we operate (collectively, the “Products”) and the services, features, advertisements or content we offer, including your communications with us or others through our messaging and phone services (collectively with the Products, the “Services”). The Policy applies when you use any of these Products or Services regardless of how you access or use the Services. This Policy describes the kinds of Data we may gather when you use the Products or Services, how we may use your Data, when we might disclose your Data, and how you can manage your Data. 

Revisions

If you do not accept all of the terms, conditions and notices set forth in the Policy, you must not use the Products or Services. Please note that our Products and Services are under constant development. This Policy may therefore be modified and updated at any time and on an ongoing basis. Each such modification will be effective upon posting on the Products and the effective date will be noted at the beginning of such revised Privacy Policy. Your continued use of the Products or Services after Operator posts a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. Therefore, you should review the Privacy Policy periodically so that you are up to date on our most current policies and practices.

Collection of Information from Children

The Products and Services are not directed to, or intended for use by, anyone under the age of 18. If you are under the age of 18, you only may use the Products and Services with permission from your parents or legal guardians. Operator does not knowingly collect personally identifiable information from users under the age of 18. If you are under the age of 18, do not use or provide any information on any of the Operator’s Products or Services (websites, apps, etc.) or through any of its features, register on any of the Operator’s Products or Services (websites, apps, etc.), make any purchases through any of the Operator’s Products or Services (websites, apps, etc.) use any of the interactive or public comment features of the Operator’s Products or Services (websites, apps, etc.) or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If a child under 18 submits information through any part of the Products or Services, and we become aware that the person submitting the information is under 18, we will delete this information. If you believe we might have any information from or about a child under 18, please contact us at info@spironsolutions.net.

Information Collected

Type of Information Collected. When you use the Products or Services, we may collect several types of information about you and/or your use of the Products or Services. The general categories of information include Personally Identifiable Information or “PII” as well as non-personally identifiable information (“non-PII”). 

PII includes, but is not limited to, the following:

• Information you provide to us. We collect your personal data or information when you use our Services.  There are numerous circumstances where you may volunteer, be required or invited to provide us with personal information, such as when you create an account, enter a contest, subscribe to our publications, newsletters, and other content, register for or use our Products or Services, submit content or post a comment, send us an e-mail or request information, or send messages through our Message Center (including e-mail, text or other messages). This information may include:
  • Your name, any alias, e-mail address, street address, and telephone number(s);
  • Employment information or other demographic information including but not limited to job title and place of employment
  • Audio, digital, video, or other electronic information provided by you, including, but not limited to, audio and/or video recordings; 
  • You may also provide us with your bank account number, credit card number, debit card number when making an online purchase of our products or services.
• Account information. We may assign you a user id, account name, unique personal or online identifier, other identifiers that permit physical or online contact with you, or any information about you collected online and maintained in personally identifiable form in combination with any of the preceding categories.
• Usage Information. We may collect certain usage information associated with you. This may include:
  • Your interaction with the Products or Services, your advertising preferences, and your communications with us or through us, the user segment or category into which you as a user are classified by us internally;
  • Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Products and Services;
  • Data that is generated as part of your purchases for Products and Services;
  • Data that is generated through your communications through use of the Products and Services, including your communications with us, our third-party providers, or other users of the Services (including, but not limited all messages and data generated through the Contact Form).
• Information from Third Parties. We may receive information about you from third parties consistent with relevant law and combine it with information we receive from or about you, including, information from plug-ins or applications.
  • When you link your account to any other account on third-party web site, including but not limited to a social media web site, we may have access to data regarding your use of that web site as well as personal data such third party web sites may have collected about you.
  • Engagement with our Products and Services through third-party social networking sites or social media plug-ins and applications; and Non-PII includes information about your use of the Products and Services. We may collect information about your use of the Products and Services including: 
• Device information. We may collect your computer or mobile device model, IP address, operating system version, browser type, language and settings, device type and settings, and other unique device identifiers.
• Location information. We may collect your location when using the Products and services on our website and apps.  We may collect and store your device's source IP address and/or latitude and longitude, which may disclose your device's approximate or precise location when you access the Products or Services. Advertisements and certain content, including from third parties, may be directed to you based on this data.
• Usage information. We may collect information about the Products or Services you use, the time, duration, and date of your use of the Services, your interaction with content offered through the Products and Services, how you contacted the Products or Services, search terms used, and browsing history. We also collect information stored using cookies, mobile ad identifiers, and similar technologies set on your device. Our servers may automatically keep an activity log of your use of the Products or Services.
• Inferential Data. We may use your personal information or other information we collect from you or your activity on the Operator’s web sites to create consumer profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. 

Certain features available within the Products or Services will require you to submit PII about yourself as a condition of participation. Some of the features may be offered by us, while others may be offered by third parties. (For example, you may be required to submit PII in order to enter a contest we conduct, to order certain products and services we offer, or to receive news updates by email from a third-party news source.) When you choose to submit PII to a third party in connection with your use of the Products or Services, the third party’s privacy policy, rather than this Policy, will control the use of your PII. YOU CAN ALWAYS REFUSE TO PROVIDE PII TO US, BUT THIS MAY RESULT IN DECREASED FUNCTIONALITY OF ANY OF THE OPERATOR’S WEB SITES FOR YOU AND LIMIT YOUR ABILITY TO RECEIVE INFORMATION ABOUT PRODUCTS OR SERVICES THAT MAY BE OF PARTICULAR INTEREST TO YOU.

How Information is Collected

We collect information both actively and passively. For example, we will collect information about you that you voluntarily provide while using the Products and Services. In addition to information provided directly by you, we (and third parties that offer features through the Products or Services) may collect non-PII through the use of “cookies,” “web beacons,” or by other electronic means. Please see the Cookie Policy below for more information.

Information We Collect Automatically. If you use the Products or Services, read or download information from the Products or Services, your web or mobile browser may automatically send us your internet or other network activity.

Information You Give To Us and Information We Collect From Others. If you use the Products or Services, or you otherwise use or purchase our Products or Services, we receive and store information you enter on the Products or Services, or that you give us in-person, via telephone, email, or otherwise. We may also collect personal information from third parties that operate (a) portions of the Products or Services on our behalf or (b) independent websites. When we obtain personal data from third parties, we will treat the acquired information like the information that we collect ourselves.

Cookie Policy: How We Collect Information From You and From Other Third Parties

We may place, or allow to be placed, cookies, web beacons and similar technologies on our Products and Services to store your username for easy logon, store your preferences, keep you logged in, perform analytics, analyze traffic, personalize content, and offer advertisements that match your interest. We may use these technologies to collect information when you use our Products and Services such as your IP address, web browser, mobile network information, browsing and conversion information in order to provide you with a customized user experience. These technologies may include Google Analytics and similar providers. You can learn more about how Google uses the information collected through this service at: www.google.com/policies/privacy/partners/. 

• Cookies. In general, a cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive, where it can be used to identify your computer. Cookies can be used to measure website usage, improve navigation around website, and personalize a returning visitor’s experience on the website. In most cases, you can set your browser to turn off cookies or to notify you before you receive one so that you can decide whether to accept it or not. Because cookies allow you to take advantage of some of the features on the Site, we recommend that you leave them turned on. If you block or reject our cookies, some of the features on the Products may not work for you. You can refer to the instructions for your browser to learn more about these functions.

• Web Beacons. We, our third-party service providers, advertisers and partners also may use “web beacons” or similar technologies. Web beacons are small strings of code placed on a web page to collect data about how visitors use the Products or Services. For example, web beacons may be used to count the number of users who visit the Products or Services, or to deliver a cookie to the browser of a visitor to the Products or Services. If you set your browser to turn off cookies, web beacons and similar technologies will detect your visits to the Products or Services, but they will not associate your activity on the Products or Services with information that otherwise would be stored in cookies. 

Social Media. We or Our third-party service providers, advertisers, and partners may use technologies like cookies, web beacons, pixel tags, device or other identifiers and local storage to identify parts of the Products and Services you have visited and/or purchased, identify advertisements you have seen, and otherwise deliver, secure, and understand products, services and ads, on and off Facebook, Instagram, Twitter, LinkedIn, YouTube, and other social media platforms. These technologies also may be used to gather information for remarketing to similar audiences on our Products. Third party advertisements displayed on the Products may also contain cookies set by third party advertisers. The Operator does not control these cookies and is not responsible for the content or practices of any linked site; users of the Products and Services should check the privacy policy of the third-party advertiser to see whether and how it uses cookies.

How Information Is Used and Shared

We may use information we collect to do the following, among other things:

• To present the Operator’s websites and its contents to you;
• To offer the Products and Services;
• To monitor and analyze web traffic and online behavior for search engine optimization and social media marketing;
• To manage security, including monitoring individuals with access to the Products and Services, applications, systems, or facilities, investigation of threats, and as needed, for any data security breach notification;
• To provide you with information, products or services that you request from us or from other users of the Operator’s web sites;
• To fulfill any other purposes for which you provide us information;
• To allow you to interact with the messaging and social networking functionalities as well as to participate in other interactive features associated with the Operator’s web sites;
• To notify you about changes to the Operator’s web sites or any products or services we offer or provide through it;
• To contact you;
• To respond to your inquiries;
• To provide notices with respect to your account;
• To troubleshoot or provide you with technical support;
• To create and to manage your account;
• To place calls or send text messages through automated means that include prerecorded messages that include advertising or non-advertising messages;
• To place calls or send text messages manually that include advertising or advertising-related information;
• To send you communications you have requested, including e-mails, newsletters and other electronic communications;
• To enroll you in contests, programs or other offers you request;
• To inform you about other products and services that may be of interest to you;
• To process payment for purchases you have made;
• To protect against or identify possible fraud;
• To manage and mitigate risk;
• View and incorporate content hosted on external sites;
• To resolve a dispute;
• To conduct a poll or survey;
• To analyze the use of our Products and Services;
• To personalize the content of our Products and Services;
• To develop new products and services;
• To improve our Products, Services and overall business;
• To understand how you arrived at the Products or Services;
• To manage the Products and Services;
• To enforce our Terms of Use and any other user agreements incorporated by reference; 
• To enforce the terms of this Policy; 
• To enforce our legal rights;
• To comply with the law; 
• For other uses we may disclose to you at the point of collection, as authorized by you, or as otherwise permitted by law, and 
• For any other purposes with your consent.

Video Services 

Your video content viewing and associated media consumption activities (collectively “Viewing Activities”) may be collected when you use the Services. By watching video content on or through the Services, you are consenting to share your personal information, together with your Viewing Activities, with third parties acting on our behalf and with our advertising and analytic partners described in this Policy in the ordinary course of business. 

Forums

The Products and Services may include forums (such as message boards, chat rooms, comment boards, and reviews) that enable users to post a comment or communicate with each other. The Operator is under no obligation to moderate or edit the forums and will not be responsible for the content or use of any material posted on any forum within the Products or Services. The Operator retains the right to delete at any time and for any reason any material posted within the Products or Services.

Information Security

The Operator protects data using administrative, technical, and physical safeguards developed and used by platforms used to create and manage the website, customer relationship management tool (CRM), and cloud storage. When we use other third-party service providers, we ask those providers to implement similar safeguards. However, we cannot guarantee that your information is completely secure either within the Company or on the systems of third-party service providers.

But we have no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites on our Products or through our Services. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

Additionally, and as you are likely aware, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications will always remain secure. Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to the Operator’s web sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on any of the Operator’s web sites.

In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission's website at http://www.consumer.ftc.gov/ for information about how to protect against identity theft.

How Long Do We Keep Your Personal Data?

We retain personal data we collect from you when we have an ongoing legitimate business need to do so (i.e., to provide you with the Services you have requested or to comply with applicable legal requirements). When we no longer have an ongoing legitimate business need to process your personal information, we will physically destroy, delete or anonymize it. 

General Contact Information

If you have any questions regarding this Privacy Policy or exercising any of your privacy rights, please contact us at info@spironsolutions.net.

Your State Privacy Rights

If you are a California, Colorado, Connecticut, Nevada, Utah or Virginia resident, your state’s laws may provide you with additional rights regarding our use of your personal information. Please see the state-specific sections below:

Important Information for California Residents: Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Product and Services that 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 us at info@spironsolutions.net.

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018, as amended and together with all applicable regulations (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For example, the definition of “personal information” under the CCPA includes your name, but also more general information such as age.

Notice of Collection

The categories of personal information that we may have collected – as described by the CCPA – in the past 12 months are:

Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name. We may use this data to provide customers with an account, enabling them to post listings or messages, or subscribe to our newsletters. Additionally, we use online identifiers to understand how consumers use our products and services.

Customer records information: name, address, telephone number, bank account number, credit, or debit card number. We collect this information when a user provides it to us through a form or email or performs an online payment transaction for our services.

Internet or other electronic network activity information: We collect this data specific to our websites and applications. We do not operate a web browser or search technology, but we track searches performed on our website. We do this for a few purposes. 

Geolocation data: We use data provided by your search engine to determine the location from which website pages were accessed but we do not store this information. Please view your web browser’s privacy policy for more information.

Inferences: We may use consumer behavior to create profiles and make inferences about future consumer behavior. 

We collect and use these categories of personal information for the business purposes and sharing practices described in our policy above.

We do not “sell” personal information. 

Right to Know and Delete

If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months (also called a data portability request). In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: if sold, personal information categories that each category of recipient purchased, and if disclosed for a business purpose, the personal information categories that each category of recipient obtained;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please submit a request here. You may also contact us at info@spironsolutions.net. We will use the information you provide to us solely for the purpose of verifying your request and locating your data, if any, within our records. Please note, under California law, such requests can be made a maximum of twice per twelve-month period.

We have a duty as the holder of certain personal information to verify your identity when making requests to know or delete personal information and to ensure that dissemination of that information would not cause harm to you if it were distributed to another person. To verify your identity, we will request and collect additional personal information from you to match it against our records. We may ask for additional information or documentation if we feel it is necessary to confirm your identity with the necessary degree of certainty. We may communicate with you through email, a secure message center, or other reasonably necessary and appropriate means. We do have the right to deny requests under certain circumstances. In such cases, we will notify you of the reasons for denial. We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks. 

Right to Opt-Out

Under California state law, users have a right to opt out of the selling or sharing of their collected data. To make an opt out request, please contact info@spironsolutions.net.

Non-discrimination

You have the right not to receive discriminatory treatment by us for exercising any of your rights.

Authorized Agent

You may be entitled, in accordance with applicable law, to submit a request via an authorized agent acting on your behalf. To do so, we must receive written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

California Do Not Track Disclosure

Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. Right now, there is no industry standard for how companies should respond to “do not track” signals, although one may be adopted in the future. We do not respond to “do not track” signals at this time. If we do so in the future, we will modify this Policy accordingly. More information about “do not track” is available at www.allaboutdnt.com.

Important Information for Colorado Residents: Your Colorado Privacy Rights

These additional disclosures for Colorado residents apply only to individuals who reside in Colorado. The Colorado Privacy Act provides additional rights to confirm and access, correct, delete, obtain a copy, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CPA, which may be broader than their common meaning.

Notice of Collection

The categories of personal information that we may have collected in the past 12 months are:

Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name. We may use this data to provide customers with an account which enables them to post listings or messages, or to subscribe to our newsletters. Additionally, we use online identifiers to understand how consumers use our products and services.

Customer records information: name, address, telephone number, bank account number, credit, or debit card number. We collect this information when a user provides it to us through a form or email or performs an online payment transaction for our services.

Internet or other electronic network activity information: We collect this data specific to our websites and applications. We do not operate a web browser or search technology, but we may track searches performed on our website. We do this for a few purposes. 

Geolocation data: We use data provided by your search engine to determine the location from which website pages were accessed but we do not store this information. Please view your web browser’s privacy policy for more information.

Inferences: We use consumer behavior to create profiles and make inferences about future consumer behavior.

We collect and use these categories of personal information for the business purposes and sharing practices described in our policy above.

We do not “sell” personal information. 

What Are My Rights Under the CPA? If you are a Colorado resident and are engaged in a direct business relationship with Company as a consumer for the provision of the Sites or Services, you may have the following rights:

• Right to Know and to Access. You may confirm whether or not we are processing your personal data. You may also request access to your personal data.

Though you may request specific pieces of your personal information that we have collected, we may not provide the following information in order to protect the security of such information: credit and debit card number and CVV numbers which were used to process online purchases of products.

• Right to Correct. You may request the correction of any inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• Right to Delete. Under certain, limited circumstances, you may request that we delete personal information that we have collected from you or from a third party. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.
• Right to Obtain a Copy. You may request a copy of your personal data, which you previously provided to us, in a portable and readily usable format to the extent that it is technically feasible to do so.
• Right to Opt Out. You may opt out of the processing of your personal data for the purposes of: i) targeted advertising, ii) the sale of personal data, or iii) profiling that may have a legal or other significant impact. 

To exercise any of these rights, please submit a request here. You may also contact us at info@spironsolutions.net. We will use the information you provide to us solely for the purpose of verifying your request and locating your data, if any, within our records.

Non-discrimination

You have the right not to receive discriminatory treatment by us for exercising any of your rights.

Authorized Agent

You may be entitled, in accordance with applicable law, to submit a request via an authorized agent acting on your behalf. To do so, we must receive written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Important Information for Connecticut Residents: Your Connecticut Privacy Rights

These additional disclosures for Connecticut residents apply only to individuals who reside in Connecticut. The Connecticut Data Privacy Act provides additional rights to confirm and access, correct, delete, obtain a copy, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CTDPA, which may be broader than their common meaning.

Notice of Collection

The categories of personal information that we may have collected in the past 12 months are:

Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name. We may use this data to provide customers with an account which enables them to post listings or messages, or to subscribe to our newsletters. Additionally, we use online identifiers to understand how consumers use our products and services.

Customer records information: name, address, telephone number, bank account number, credit, or debit card number. We collect this information when a user provides it to us through a form or email or performs an online payment transaction for our services.

Internet or other electronic network activity information: We collect this data specific to our websites and applications. We do not operate a web browser or search technology, but we may track searches performed on our website. We do this for a few purposes.

Geolocation data: We use data provided by your search engine to determine the location from which website pages were accessed but we do not store this information. Please view your web browser’s privacy policy for more information.

Inferences: We use consumer behavior to create profiles and make inferences about future consumer behavior.

We collect and use these categories of personal information for the business purposes and sharing practices described in our policy above.

We do not “sell” personal information.

What Are My Rights Under the CTDPA? If you are a Connecticut resident and are engaged in a direct business relationship with Company as a consumer for the provision of the Sites or Services, you may have the following rights:

• Right to Confirm and to Access.      You may confirm whether or not we are processing your personal data. You      may also request access to your personal data.
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Though you may request specific pieces of your personal information that we have collected, we may not provide the following information in order to protect the security of such information: bank account numbers or other financial information, account passwords or security questions and answers.

• Right to Correct. You may request the correction of any inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• Right to Delete. Under certain, limited circumstances, you may request that we delete personal information that we have collected from you or from a third party. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.
• Right to Obtain a Copy. You may request a copy of your personal data, which you previously provided to us, in a portable and readily usable format to the extent that it is technically feasible to do so.
• Right to Opt Out. You may opt out of the processing of your personal data for the purposes of: i) targeted advertising, ii) the sale of personal data, or iii) profiling      that may have a legal or other significant impact. 

To exercise any of these rights, please submit a request here. You may also contact us at info@spironsolutions.net. We will use the information you provide to us solely for the purpose of verifying your request and locating your data, if any, within our records.

Non-discrimination

You have the right not to receive discriminatory treatment by us for exercising any of your rights.

Authorized Agent

You may be entitled, in accordance with applicable law, to submit a request via an authorized agent acting on your behalf. To do so, we must receive written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Important Information for Nevada Residents: Your Nevada Privacy 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. 

We do not “sell” personal information.

Important Information for Utah Residents: Your Utah Privacy Rights

These additional disclosures for Utah residents apply only to individuals who reside in Utah. The Utah Consumer Privacy Act provides additional rights to confirm, access, delete, obtain a copy, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the UCPA, which may be broader than their common meaning.

Notice of Collection

The categories of personal information that we may have collected in the past 12 months are:

Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name. We may use this data to provide customers with an account which enables them to post listings or messages, or to subscribe to our newsletters. Additionally, we use online identifiers to understand how consumers use our products and services.

Customer records information: name, address, telephone number, bank account number, credit, or debit card number. We collect this information when a user provides it to us through a form or email or performs an online payment transaction for our services.

Internet or other electronic network activity information: We collect this data specific to our websites and applications. We do not operate a web browser or search technology, but we may track searches performed on our website. We do this for a few purposes. 

Geolocation data: We use data provided by your search engine to determine the location from which website pages were accessed but we do not store this information. Please view your web browser’s privacy policy for more information.

Inferences: We use consumer behavior to create profiles and make inferences about future consumer behavior.

We collect and use these categories of personal information for the business purposes and sharing practices described in our policy above.

We do not “sell” personal information. 

What Are My Rights Under the UCPA? If you are a Utah resident and are engaged in a direct business relationship with Company as a consumer for the provision of the Sites or Services, you may have the following rights:

• Right to Confirm and to Access. You may confirm whether or not we are processing your personal data. You may also request access to your personal data.

Though you may request specific pieces of your personal information that we have collected, we may not provide the following information in order to protect the security of such information: social security numbers, driver’s license or other state or government-issued identification numbers, bank account numbers or other financial information, any health insurance or medical identification numbers or related information, account passwords or security questions and answers.

• Right to Delete. Under certain circumstances, you may request that we delete personal information that we have collected from you or from a third party. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.
• Right to Obtain a Copy. You may request a copy of your personal data, which you previously provided to us, in a portable and readily usable format to the extent that it is technically feasible to do so.
• Right to Opt Out. You may opt out of the processing of your personal data for the purposes of: i) targeted advertising, or ii) the sale of personal data.

To exercise any of these rights, please submit a request here. You may also contact us at info@spironsolutions.net. We will use the information you provide to us solely for the purpose of verifying your request and locating your data, if any, within our records.

Non-discrimination

You have the right not to receive discriminatory treatment by us for exercising any of your rights.

Authorized Agent

You may be entitled, in accordance with applicable law, to submit a request via an authorized agent acting on your behalf. To do so, we must receive written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Important Information for Virginia Residents: Your Virginia Privacy Rights

These additional disclosures for Virginia residents apply only to individuals who reside in Virginia. The Virginia Consumer Data Protection Act provides additional rights to confirm and access, correct, delete, obtain a copy, and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CDPA, which may be broader than their common meaning. 

Notice of Collection

The categories of personal information that we may have collected in the past 12 months are:

Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name. We may use this data to provide customers with an account which enables them to post listings or messages, or to subscribe to our newsletters. Additionally, we use online identifiers to understand how consumers use our products and services.

Customer records information: name, address, telephone number, bank account number, credit, or debit card number. We collect this information when a user provides it to us through a form or email or performs an online payment transaction for our services.

Internet or other electronic network activity information: We collect this data specific to our websites and applications. We do not operate a web browser or search technology, but we may track searches performed on our website. We do this for a few purposes. 

Geolocation data: We use data provided by your search engine to determine the location from which website pages were accessed but we do not store this information. Please view your web browser’s privacy policy for more information.

Inferences: We use consumer behavior to create profiles and make inferences about future consumer behavior. 

We collect and use these categories of personal information for the business purposes and sharing practices described in our policy above.

We do not “sell” personal information.