At Spread, we believe that privacy is a right. In order to
ensure transparency and give you more control over your personal
information, this privacy policy (“Privacy Policy”) governs how we,
Spread Social, Inc. (“Spread”, “we”, “our” or “us”) use, collect and
store personal information that we collect or receive from or about
you (“you”) in connection with https://joinspread.com/ (“Website”),
the mobile application (“App”) and the services provided therein (the
App, Website, Platform and the services provided, shall, collectively,
be referred to as the “Services”).
Spread’s mission is to
enable access to the ideas that matter by designing a platform for
superior discovery and productive information gathering
(“Platform”).
We greatly respect your privacy, which is why
we make every effort to provide a Platform that would live up to the
highest user privacy standards. Please read this Privacy Policy
carefully, so you can fully understand our practices in relation to
personal information.
Important note: Nothing in this
Privacy Policy is intended to limit in any way your statutory rights,
including your rights to a remedy or other means of enforcement.
Table
of contents
1. What personal information we collect, why we collect it, and how
it is used
2. How we protect and retain your personal
information
3. How we share your personal information
4.
Your privacy rights
5. International transfers of personal
information
6. Use by children
7. Interaction with third
party products
8. Analytic tools/ Cookies
9. Specific
provisions applicable under California privacy law
10. Contact
us
This Privacy Policy can be updated from time to time
and, therefore, we ask you to check back periodically for the latest
version of this Privacy Policy. If we implement material changes in
the way we use your personal information, in a manner that is
different from that stated at the time of collection, we will notify
you by posting a notice on our Website or App or by other means and
take any additional steps as required by applicable law.
1.
WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS
USED
1.1 We Process The Following Personal Information:
1.1.1 Information You Decide To Provide Us With. We
collect personal information that you voluntarily provide us with,
such as when you create an account on the Website or the App, or when
you decide to join our Waitlist. The personal information will include
your full name, email address, profile picture provided by you or your
chosen log-in provider (such as Google or Apple) as well as any other
information that you decide to provide us with.
1.1.2 Information
Provided When Using The Services. When you use the Services and/or
submit any content, we collect and process the personal information
submitted, such as posts, reports or any other content that you choose
to upload to the Services. We also process any other personal
information made available as part of your interaction with the
Services, like the lists of accounts followed by you on the Platform
and/or any actions you take with regard to the content you or other
users post, such as reposting other users’ content.
1.1.3
Information Automatically Collected. We may automatically collect
certain information through your use of Spread’s Services, such as
cookie, pixels, tracking technologies and similar identifiers
(“Technologies”), your Internet protocol (IP) address, and other
device identifiers that are automatically assigned to your device,
browser type and language, geo-location information, hardware type,
operating system, internet service provider and other information
about actions taken through the use of the Services.
1.1.4
Information From Other Sources. Spread may also obtain information
about you from other sources, including publicly – or commercially-
available information, and through third-party data platforms,
partners, and service providers. Such information may include profile
pictures, lists of followers or any other information made available
to us by you and the applicable third party.
1.1.5 Information
You Provide To Us In Person. For example, when you attend one of our
events and you provide us with your contact details. We will use this
information to answer your enquiries or provide additional information
to you.
1.2 We Process Information For The Following
Purposes:
1.2.1 To Provide You With The Services. We will
use the information, including, without limitation, for the following
purposes: (i) to allow you to create an account; (ii) to provide you
the Services and to process your requests; (iii) to communicate with
you about your use of the Services; (iv) to fulfill any instruction
and/or request made by you in the context of the Services; (v) to send
you push notifications and/or emails and notifications regarding your
account or certain features of the Services, including, updates
pertaining to your subscription, and related to the Services we
provide you with; (vi) to personalize your experience with our
Services; (vii) to allow you to create more users and administrate
your users; (viii) to generally administer and improve the
Services.
1.2.2 To Allow You To Make Use Of Our Website And App.
We will use your information to allow you to make use of our Website
and/or App, including, (i) to answer your questions and to allow you
to communicate with us (e.g., by using the Website chat); (ii) to
analyze your use of our Services and to improve our Website and/or
App; and (iii) to customize your experience.
1.2.3 For
Administrative Purposes. Spread may use your information, (i) to
respond to your questions, comments, and other requests for customer
support, or information, including information about potential or
future services; (ii) to provide you with the Services; (iii) for
internal quality control purposes; (iv) to establish a business
relationship; (v) to generally administer the Services.
1.2.4 To
Market Our Services. Spread may use your information to market the
Services. Such use includes (i) notifying you about offers and
services that may be of interest to you; (ii) tailoring content (iii)
developing and marketing new products and services, and to measure
interest in the Services; (iv) other purposes disclosed at the time
you provide the information; and (v) as you otherwise approve;
1.2.5
Security Purposes. Some of the above-mentioned information will be
used for detecting, taking steps to prevent and prosecuting fraud or
other illegal activity; to identify and repair errors; to conduct
audits; and for security purposes. Information may also be used to
comply with applicable laws, with investigations performed by the
relevant authorities, law enforcement purposes, and/or to exercise or
defend legal claims.
1.2.6 De-Identified And Aggregated
Information Use. In certain cases, we may or will anonymize or
de-identify your Information and further use it for internal and
external purposes, including, without limitation, to analyze and
improve the Services (including through the use of artificial
intelligence) and for research purposes. We may use this anonymous or
de-identified information and/or disclose it to third parties without
restrictions (for example, in order to improve our Services and
enhance your experience with them and/or to develop new product
features and improve existing offerings).
1.2.7 Cookies And
Similar Technologies. We, as well as third parties that provide
content, advertising, or other functionality on the Services, use
Technologies to automatically collect information through the
Services. We use Technologies that are essentially small data files
placed on your device that allow us to record certain pieces of
information whenever you visit or interact with the Services. If you
would like to opt-out of the cookies and similar technologies we
employ on the Services, you may do so by blocking, deleting, or
disabling them as your browser or device permits.
1.3 The
Lawful Bases We Rely On For Processing Personal Information Are (If
And When Applicable):
1.3.1 The data subject has given
consent to the processing of his or her personal information;
1.3.2
Processing is necessary for the performance of a contract to which the
data subject is a party or in order to
take steps at the request
of the data subject prior to entering into a contract; and/or
1.3.3
Processing is necessary for the purposes of the legitimate
interest.
2. HOW WE PROTECT AND RETAIN YOUR PERSONAL
INFORMATION.
2.1 Security. We have implemented and maintain
reasonable technical, organizational and security measures designed to
protect your information. However, please note that we cannot
guarantee that the information will not be compromised as a result of
unauthorized penetration to our servers. As the security of
information depends in part on the security of the computer, device or
network you use to communicate with us and the security you use to
protect your user IDs and passwords, please make sure to take
appropriate measures to protect this information.
2.2
Retention Of Your Information. Your information will be stored until
we delete our records, and we proactively delete it, or if you send a
valid deletion request. Please note that in some circumstances we may
store your information for longer periods of time, for example (i)
where we are required to do so in accordance with legal, regulatory,
tax or accounting requirements; or (ii) for us to have an accurate
record of your dealings with us in the event of any complaints or
challenges; and/or (iii) if we reasonably believe there is a prospect
of litigation relating to your information or dealings.
3.
HOW WE SHARE YOUR PERSONAL INFORMATION. We may share your information
as follows:
3.1 The information we gather is shared with
our partners and other third parties.
3.2 We may also share
information with our affiliated companies about you.
3.3 We may
use third party service providers to process your information for the
purposes outlined above, including, without limitation:
3.3.1
With cloud service providers for hosting purposes.
3.3.2 With
websites and web content creation platforms in order to help us manage
our Services.
3.3.3 With email providers, marketing, CRM, other
similar tool providers.
3.3.4 With analytic companies, in order
to help us understand and analyze information we collect in accordance
with this policy.
3.4 To the extent necessary, with
regulators, courts, banks or competent authorities, to comply with
applicable laws, regulations and rules (including, without limitation,
federal, state or local laws), and requests of law enforcement,
regulatory and other governmental agencies or if required to do so by
court order, as well as for internal compliance procedures and to
protect the safety, security, and integrity of Spread, our Services,
customers, employees, property, and the public.
3.5 If, in
the future, we sell or transfer, or we consider selling or
transferring, some or all of our business, shares or assets to a third
party, we will disclose your information to such third party (whether
actual or potential) in connection with the foregoing events
(including, without limitation, our current or potential investors).
In the event that we are acquired by, or merged with, a third party
entity, or in the event of bankruptcy or a comparable event, we
reserve the right to transfer, disclose or assign your information in
connection with the foregoing events.
3.6 Where you have
otherwise provided your consent to us for sharing or transferring your
information.
4. YOUR PRIVACY RIGHTS
4.1
The following rights (which may be subject to certain exemptions or
derogations), shall apply to certain individuals (some of which only
apply to individuals protected by specific laws):
4.1.1 You
have the right to withdraw consent to the processing, where consent is
the basis of processing.
4.1.2 You have the right to access the
personal information that we hold and request further details about
how we process it, under certain conditions.
4.1.3 You have the
right to demand rectification of inaccurate personal information about
you. We will promptly correct any information found to be
incorrect.
4.1.4 You have the right to object to unlawful data
processing under certain conditions.
4.1.5 You have the right to
the erasure of past data about you (your “right to be forgotten”)
under certain conditions.
4.1.6 You have the right to demand that
we restrict the processing of your personal information, under certain
conditions, if you believe we have exceeded the legitimate basis for
processing, the processing is no longer necessary, or if you believe
your personal information is inaccurate.
4.1.7 You have the right
to data portability of personal information concerning you that you
provided us in a structured, commonly used, and machine-readable
format, subject to certain conditions.
4.1.8 The personal
information we collect is not used for automated decision-making and
profiling, except for automated processes in the context of marketing.
As stated above, you can opt-out of direct marketing by Spread by
contacting Spread directly or by following the instructions through
the unsubscribe options in our email messages.
4.2
Exercising Your Rights: You can exercise your rights by contacting us
at
[email protected]. You may use an authorized agent to submit a
request on your behalf if you provide the authorized agent written
permission signed by you. To protect your privacy, we may take steps
to verify your identity before fulfilling your request. Subject to
legal and other permissible considerations, we will make every
reasonable effort to honor your request promptly in accordance with
applicable law or inform you if we require further information in
order to fulfill your request. When processing your request, we may
ask you for additional information to confirm or verify your identity
and for security purposes, before processing and/or honoring your
request. We reserve the right to charge a fee as permitted by law, for
instance if your request is manifestly unfounded or excessive. In the
event that your request would adversely affect the rights and freedoms
of others (for example, would impact the duty of confidentiality we
owe to others) or if we are legally entitled to deal with your request
in a different way than initial requested, we will address your
request to the maximum extent possible, all in accordance with
applicable law.
4.3 Deleting Your Account: Should you ever
decide to delete your account, you may do so by emailing
[email protected]. If you terminate your account, any association
between your account and personal information we store will no longer
be accessible through your account. However, given the nature of
sharing on certain services, any public activity on your account prior
to deletion will remain stored on our servers and will remain
accessible to the public.
4.4 Marketing Emails – Opt-Out:
You may choose not to receive marketing emails of this type by sending
a single email with the subject “BLOCK” to
[email protected].
Please note that the email must come from the email account you wish
to block OR if you receive an unwanted email from us, you can use the
unsubscribe link found at the bottom of the email to opt out of
receiving future emails, and we will process your request within a
reasonable time after receipt.
5. INTERNATIONAL
TRANSFERS OF PERSONAL INFORMATION. In order to run our business and
provide our Services to you, we transfer personal information to
certain countries around the world, including to our affiliates and
service providers, many of whom are located outside of your
jurisdiction. Therefore, your personal information may be processed in
countries with privacy laws that are different from privacy laws in
your country. Whenever we make such transfers, we will use
commercially reasonable efforts to implement an appropriate level of
protection to your personal information by implementing at least one
of the following safeguards:
5.1 making sure the
destination country has been deemed to provide an adequate level of
protection for personal information; and/or
5.2 by
executing implement data onward transfer instruments such as data
processing and protection agreements.
6. USE BY
CHILDREN. We do not offer our products or services for use by children
and, therefore, we do not knowingly collect information from, and/or
about children under the age of 18. If you are under the age of 18, do
not provide any information to us without the involvement of a parent
or a guardian. In the event that we become aware that you provide
information in violation of applicable privacy laws, we reserve the
right to delete it. If you believe that we might have any such
information, please contact us at
[email protected].
7.
INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with
third party websites, mobile software applications and products or
services that are not owned, or controlled, by us (each, a “Third
Party Service”). We are not responsible for the privacy practices or
the content of such Third Party Services. Please be aware that Third
Party Services can collect information from you. Accordingly, we
encourage you to read the terms and conditions and privacy policies of
each Third Party Service.
8. ANALYTIC
TOOLS/COOKIES
8.1 Google Analytics. We use a tool called
“Google Analytics” to collect information about use of the Services.
Google Analytics collects information such as how often users visit
the Website or the App, what pages they visit when they do so, and
what other websites they used prior to coming to the Website. We use
the information we get from Google Analytics to maintain and improve
the Services. We do not combine the information collected through the
use of Google Analytics with information we collect. Google’s ability
to use and share information collected by Google Analytics about your
visits to the Services is restricted by the Google Analytics Terms of
Service, available at
https://marketingplatform.google.com/about/analytics/terms/us/, and
the Google Privacy Policy, available at
http://www.google.com/policies/privacy/. You may learn more about how
Google collects and processes data specifically in connection with
Google Analytics at http://www.google.com/policies/privacy/partners/.
You may prevent your data from being used by Google Analytics by
downloading and installing the Google Analytics Opt-out Browser
Add-on, available at https://tools.google.com/dlpage/gaoptout/.
8.2
Mixpanel. We collect information such as your email address and your
user activity through the use of Mixpanel. Mixpanel’s ability to use
and share information is governed by the Mixpanel Terms of Use,
available at https://mixpanel.com/legal/terms-of-use/, and the
Mixpanel Privacy Policy, available at
https://mixpanel.com/legal/privacy-policy/ . You can opt-out of
Mixpanel’s services by clicking on the following link:
https://mixpanel.com/optout./
8.3 Expo. We use Expo, a
framework for creating mobile apps. Expo may collect anonymous basic
usage information (such as device info and crash reports), so they can
improve their services. We don’t have access to this information.
Please refer to Expo’s Privacy Policy for more information about their
data collection and processing practices.
8.4 UXCam. We use
UXCam, which is an analytics solution. UXCam may record: Screens
visited, Interaction patterns (such as screen actions, gestures: taps,
scrolls), and Device details (Type, Version, Model, Operating System).
We are using the information collected by UXCam to improve our app.
UXCam does not collect personally identifiable information and does
not track your browsing habits across apps. For more information see
Privacy Policy for Information Collected by the UXCam Service.
8.5
Through our Services we may allow third party advertising partners to
set technologies and other tracking tools to collect information
regarding your activities and your device (e.g., your IP address,
mobile identifiers, page(s) visited, location, time of day). We may
also combine and share such information and other information (such as
demographic information and past purchase history) with third party
advertising partners. These advertising partners may use this
information (and similar information collected from other websites)
for purposes of delivering targeted advertisements to you when you
visit third party websites within their networks. This practice is
commonly referred to as “interest-based advertising” or “online
behavioral advertising”. We may allow access to other data collected
by the services to share information that may be useful, relevant,
valuable or otherwise of interest to you.
8.6 We reserve
the right to remove or add new analytic tools, cookies, pixels and
other tracking technologies.
9. SPECIFIC PROVISIONS
APPLICABLE UNDER CALIFORNIA PRIVACY LAW
9.1 California
Privacy Rights: California Civil Code Section 1798.83 permits our
customers who are California residents to request certain information
regarding our disclosure of information to third parties for their
direct marketing purposes. To make such a request, please send an
email to
[email protected]. Please note that we are only required
to respond to one request per customer each year.
9.2 Our
California Do Not Track Notice: Do Not Track (“DNT”) is a privacy
preference that users can set in certain web browsers. Please note
that we do not respond to or honor DNT signals or similar mechanisms
transmitted by web browsers, but we may allow third parties, such as
companies that provide us with analytics tools, to collect personally
identifiable information about an individual consumer’s online
activities over time and across different websites when a consumer
uses the Services.
10. CONTACT US. If you have any
questions, concerns or complaints regarding our compliance with this
notice and the data protection laws, or if you wish to exercise your
rights, we encourage you to first contact us at
[email protected].
Last Updated: December,
2023
