Privacy Policy

When you visit our website https://www.spriv.com, mobile application, and use our services, you trust us with your personal information. In this privacy notice, we describe what we collect, how we use it, and the rights you have in relation to it. If there are any terms you do not agree with, please discontinue use of our Sites or Apps.

This privacy policy applies to all information collected through our website, mobile application ("Apps"), and any related services, sales, marketing or events (collectively, the "Sites").

Information automatically collected. Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Sites or Apps. This does not reveal your specific identity, but may include IP address, browser and device characteristics, OS, language preferences, referring URLs, device name, country, location, and technical information about how and when you use our Sites or Apps. This is primarily needed to maintain the security and operation of our Sites or Apps, and for internal analytics and reporting.

Information collected through our Apps. If you use our Apps, we may also collect:

• Mobile Device DataDevice information (mobile device ID, model, manufacturer), OS, device event information (crashes, system activity, hardware settings, browser language), and location information (via IP, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points and cell towers). Location information is used only for automating authentication of your identity.
• Push NotificationsWe may request to send you push notifications about your account or the mobile app. You can turn them off in your device's settings.
• No mobile info sharingNo mobile information will be shared with third parties or affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Information collected from other sources. We may obtain information about you from public databases, joint marketing partners, and other third parties — social media profile information, marketing leads, search results and links (including sponsored links).

We process your information for legitimate business interests, contract fulfilment, compliance with legal obligations, and/or your consent. Specifically:

• Account creation & logonWith your Consent. If you choose to link your Spriv account with a third-party account (Google, Facebook), we use the information you allowed us to collect from those third parties.
• Protecting our SitesFor Business Purposes and/or Legal Reasons — fraud monitoring and prevention.
• Enforcing terms & policiesFor Business Purposes, Legal Reasons and/or Contractual necessity.

We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

• Compliance with LawsIn response to a court order, subpoena, or governmental request (including for national security or law enforcement).
• Vital Interests & Legal RightsTo investigate, prevent or take action regarding potential violations of our policies, suspected fraud, threats to safety, or illegal activities, or as evidence in litigation.
• Third-Party Service ProvidersPayment processing, data analysis, email delivery, hosting, customer service, marketing. We do not sell, rent or trade any of your information with third parties for their promotional purposes.
• Business TransfersIn connection with a merger, sale of assets, financing, or acquisition of all or part of our business.
• With your ConsentFor any other purpose.

We may use cookies and similar tracking technologies (web beacons, pixels) to access or store information. Specifics about how you can refuse certain cookies are set out in our Cookie Policy.

We keep your personal information only as long as necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law.

We have implemented appropriate technical and organisational security measures. However, we cannot guarantee that the internet itself is 100% secure. Transmission of personal information to and from our Sites or Apps is at your own risk — you should only access the services within a secure environment.

We do not knowingly solicit data from or market to children under 18. By using the Sites or Apps, you represent that you are at least 18 or the parent/guardian of such a minor. If we learn personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we have collected from children under 18, please contact support@spriv.com.

In some regions (like the European Economic Area) you have certain rights under applicable data protection laws:

• Access & copyRequest access and obtain a copy of your personal information.
• Rectify or eraseRequest rectification or erasure of your personal information.
• Restrict processingRestrict the processing of your personal information.
• Data portabilityWhere applicable, receive your data in a portable format.
• Object & withdraw consentObject to processing, and withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before it.

If you're an EEA resident and believe we're unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority — EU DPA directory.

Account Information. To review, change, or terminate your account, log into your account settings. On request, we will deactivate or delete your account and information from our active databases. Some information may be retained to prevent fraud, troubleshoot problems, assist with investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies. Most browsers accept cookies by default. You can set your browser to remove or reject cookies — but this could affect certain features of our Sites or Apps.

Opting out of email marketing. Unsubscribe via the link in any marketing email, or contact us. You'll still receive service-related emails necessary for the administration and use of your account.

Yes. California Civil Code Section 1798.83 (the "Shine The Light" law) permits users who are California residents to request, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Submit your request in writing using the contact information below.

If you are under 18, reside in California, and have a registered account, you have the right to request removal of unwanted data that you publicly posted on the Sites or Apps. Contact us with your account email and a statement that you reside in California. We will make sure the data is not publicly displayed, but be aware that the data may not be completely removed from our systems.

Yes — we will update this policy as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated "Revised" date and will be effective as soon as it's accessible. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification.

Questions or comments about this policy? Contact our Data Protection Officer (DPO), Guy Hefetz:

• Emailsupport@spriv.com
• Post517 Grand St, 1st Floor, New York, NY 10002, United States
• Contact formContact Us page — routes to the right person within one business day.