SPAPERKS LLC PRIVACY POLICY
LAST UPDATED: June 8, 2019
At SpaPerks, we appreciate that you’re trusting us with your information, and we take many steps to protect your information and to put you in control of how we use it. This Privacy Policy outlines these steps and explains what information SpaPerks LLC (“SpaPerks,” “we,” “us,” or “our”) collects, how we collect it, why we collect it, how we use it, and how you can manage, update, export, and delete your information.
When you use our mobile app and website and any other related services, you agree to the practices we describe in this Policy.
If you have any questions about this policy or your personal information, you may reach us at:
support@spaperks.com
THE INFORMATION WE COLLECT
Information we receive from you
We collect information from you to help you find products & services available through our platform. We ask you to provide information to complete your user profile and other details about your interests, personality, and lifestyle. Some of the details you disclose, may be considered “sensitive” or “special” under the law of your jurisdiction. You may also choose to give us access to your camera, photo album, or social media account. When you choose to share this information, you consent to our processing of that information.
We also collect any content you create, share, and receive from other users while using our service. This may include emails, photos and videos, and other documents.
We may also occasionally encourage you to refer your friends to our service by sharing their email addresses. If you elect to share their emails, we will store their data in our database and enable you to send your friends information about our service; the message will also include an opportunity for your contacts to opt out and unsubscribe from our email list. You agree that you will not abuse this feature by entering the contact information of people who would not be interested in our service.
Information we collect as you use our service
By using our service, you authorize us to collect, process, review, and store the data related to our provision of this service.
When you sign up for our service, we collect your login credentials—your username and password, email address, mobile number, and payment information, along other account-related details. From time to time, we may ask to verify your information to avoid the creation of fake accounts on our service. We may also request login information and friend lists for any social media accounts that you connect to your SpaPerks account. You may access and correct your information at any time when you log on to our service.
We also collect information about the devices you use to access our service. We collect your mobile device’s unique ID number, your geographic location, and technical information about your device (including its type, IP address, operating system, browser type, time zone, advertising IDs, service provider, and signal strength).
Additionally, we may collect information about how you access and use our service. As you use SpaPerks, we collect data about how, when, and how often you access your account, including details about the features you use, the searches you run, the webpages or ads that you click on, and the webpages that referred you to our site.
We may collect, with your permission, details about your geolocation, both latitude and longitude, to help you better use our service. We may collect this information through Wi-Fi, GPS, or Bluetooth.
If you contact us, we will collect the information you share during our interaction; we may monitor or record any interaction with our customer service team to ensure we are providing high-quality service.
Information we collect from others
Other users may contact us about you relating to your use of our service. We may collect any information that they provide.
Cookies
We use cookies to count the number of visitors to our site and to recognize and authenticate you and your device. Cookies are small text files that websites put in a visitor’s browser to store their preferences, track user trends, and advertise. When you visit our service, we may receive information from your browser, including from cookies, with the goal of making your user experience more pleasant and error-free. Your browser may allow you to block or delete cookies, but if you choose to do so, our service may not work properly. We also use web beacons (sometimes called “clear gifs” or “pixel tags”) to help personalize our service for our users, collect information about you, and facilitate advertising. We may also use web beacons in email communications to help us understand user behavior, such as whether users open or take action upon receiving an email.
Social media sites
If you connect your social media account to our service, we collect public information about you, such as your name, email address, profile picture, and location, as well as any other information you authorize the social media site to share, such as a list of your friends and connections.
HOW WE USE INFORMATION
We collect data so we can provide our service. We also study data to make sure we are delivering a high-quality service for our users and to make improvements to our service. More specifically, we may use your information to:
help you create and maintain your account, including processing payments;
correspond with you regarding our service for information and operational purposes, such as customer service or system maintenance, and to respond to your inquiries;
modify or personalize our service to match your preferences;
offer services and features to you;
provide relevant advertising and other information that may be of interest to you;
study your interactions with our service and any related third-party’s online services;
aggregate your personal information;
anonymize your personal information;
detect fraud and improve the security of our service;
manage our relationships with third-party providers and partners;
evaluate and improve our business, including analyzing how users access and use the service;
resolve disputes between you and other users of our service;
enforce legal agreements and rights related to our service; and
comply with laws, regulations, industry standards, and our policies.
We may process your personal information for these purposes in the following circumstances:
you have consented to the use of your personal information;
we need your personal information to provide you with services and products that you have requested or to respond to your inquiries;
we have a legal obligation to use your personal information; or
we or a third party have a legitimate interest in using your personal information to ensure and improve the safety, security, and performance of our service.
HOW WE MAY SHARE YOUR PERSONAL INFORMATION
Our goal is to help you find products on our platform that as of interest to you, so we facilitate the sharing of your information in that regard. Otherwise, we do not sell or otherwise disclose the personal information that we collect about you, except as described in this policy or as we disclose at the time that we collect your data.
Sharing With Our Service Providers and Partners
We work with third parties to help us operate and improve our service. Third parties may participate in various tasks, including data hosting and maintenance, data analytics, customer care, marketing and advertising, payment processing, and security. We may share information with these providers only as necessary to perform services on our behalf. All of our third-party partners must agree to strict confidentiality obligations.
Sharing As Required by Law
We may disclose your information, without notice or consent, if reasonably necessary to comply with a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirement; to assist in the investigation, prevention, or detection of crime (subject to applicable law); or to protect the safety of any person.
We may also share information to mitigate our liability in an actual or threatened lawsuit; to protect our legal rights and legal rights of our users, business partners, or other interested parties; to enforce our agreements with you; and to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.
Finally, we may transfer your information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.
With Your Consent or at Your Request
We may ask for your consent to share your information with third parties. In any such case, we will explain why we want to share the information.
We may use and share nonpersonal information—information that does not specifically identify you and that may have been anonymized—in any of the circumstances described above, including with third-parties to develop and deliver targeted advertising on our service and on websites or applications of third parties and to analyze and report on advertising you see, as permitted by law.
YOU HAVE RIGHTS AND CHOICES WHEN IT COMES TO YOUR DATA
Account Information
Through your account settings, you can update your personal information at any time. You may also delete your account directly from our service. You can also uninstall our app to stop all information collection. If you uninstall the app without deleting your account, we will continue to store the unique identifier associated with your account; we will re-associate this identifier with your account if you reinstall the application on the same mobile device.
Location Information
We use your location to optimize your use of the service. However, you can prevent us from collecting location information from your device by changing the settings on your device.
Marketing Opt-Out
From time to time, we may send messages about our service as well as promotional messages. If you prefer, you can unsubscribe from promotional emails from us at any time via a link at the bottom of each email.
Other Rights
Depending on your jurisdiction, you may have the right to request access to and to receive information about the personal information we collect and store about you; to update and correct inaccuracies in your personal information; to restrict or object to the processing of your personal information; to have us anonymize or delete your personal information; or to exercise your right to data portability to transfer your personal information to another company. In some circumstances, these rights may be limited by local law requirements. In addition to these rights, you may also have the right to lodge a complaint with a competent data supervisory authority subject to applicable law.
Where required by law, we will obtain your consent for the processing of certain personal information that we collect via cookies or similar technologies or that we use to send you direct marketing communications, to collect your location information, or to effectuate other processing activities for which your consent may be required. If we rely on consent to process your personal information, you have the right to withdraw that consent at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
To update your preferences, ask us to remove your information from our mailing lists, delete your account, or submit a request to exercise your rights under applicable law, please contact us at support@spaperks.com.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We take steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. Although we take steps to protect your information, there is no 100 percent guarantee of security when it comes to the internet. Therefore, we cannot ensure or warrant the security of any personal information that you provide to us, subject to requirements under applicable law to ensure or warrant information security.
We maintain administrative, technical, and physical safeguards that are intended to protect our users’ personal information against accidental or unlawful destruction or loss, unauthorized alteration or disclosure, or access, misuse, and any other unlawful form of processing of the personal information in our possession. In particular, we use security methods and procedures designed to safeguard personal information during transmission and storage.
If we suspect or detect a security breach, we may suspend your use of all or part of our service. If you believe that your account or information is no longer secure, please notify us immediately by emailing support@spaperks.com.
By providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the site or by sending an e-mail to you. You may have a legal right to receive this notice in writing.
We only keep your personal information as long as we need it for legitimate business purposes and legal requirements. After this period expires, or upon your request, we will delete your personal information or keep it in a form that does not identify your information.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.
DATA TRANSFERS AND INTERNATIONAL USERS
SpaPerks LLC is based in the United States. Personal information that we collect may be transferred to, processed in, and stored at, any of our affiliates, partners, or service providers that may be located anywhere around the world, including in the United States. By submitting your personal data, you agree to this transfer, processing, and storage. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. If we transfer or disclose your personal information to other countries, we will protect that information as described in this Privacy Policy. Where required by law, international transfers of personal information will be supported by an adequacy mechanism.
If you are a resident of the European Union, you may ask whether we are processing personal information about you, request access to your personal information, and ask that we correct, amend, delete, or restrict processing of your personal information. In addition, you may object to our processing of your personal information at any time. Doing so may limit your use of our service.
RESIDENTS OF CALIFORNIA
California Civil Code section 1798.83, the state’s “Shine the Light” law, allows California consumers to request information about certain businesses’ practices related to disclosing personal information to third parties for direct marketing purposes. If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to support@spaperks.com. To protect all of our users, including you, we may ask for provide proof of your identity before we can answer your request.
Occasionally, we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. If you want us to stop sharing your contact information with third parties, notify us at support@spaperks.com. If you have opted out as described above, and thereafter you choose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals from web browsers or other similar mechanisms that give consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third-party online services, to the extent the operator engages in that collection. Because there is currently no accepted standard for how to respond to do not track signals, our website does not currently respond to these signals. By using our service or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the service or by sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@spaperks.com.
Under California Civil Code § 1789.3, California residents may report complaints about the use of their personal information to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, 400 R Street, Sacramento, CA 95814. You may also contact the Unit at (800) 952-5210.
THIRD-PARTY SITES
Our service may contain links to third-party websites and services. If you choose to click on a third-party link, you will be directed to that third party’s website or service. Any link from our service to a third-party website or service is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or services. These third parties may place their own cookies or other files on your computer or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information that you submit to them. We encourage you to read the privacy policies or statements of the other websites and services that you visit.
CHILDREN’S PRIVACY
Our service is limited to users who are 18 years of age or older. Users under 18 are not permitted to use our platform. We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”), from children under 13 years of age, and no part of our service is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at support@spaperks.com. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account. If we delete an account because of this rule, we may retain your email and IP address to prevent you from creating another profile.
Your access to the our service and this Privacy Policy are governed and interpreted by the laws of the Commonwealth of Virginia, other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the Commonwealth of Virginia. By using our service, you are consenting to the exclusive jurisdiction of the courts of the United States and the Commonwealth of Virginia. You agree that such courts shall have personal jurisdiction over you and are the proper venue for any of your legal claims and waive any objection based on inconvenient forum.
UPDATES TO THIS PRIVACY POLICY
From time to time, we may update this policy. We will notify you by email or as otherwise required by applicable law. We will post any adjustments to this Privacy Policy on this webpage and update the “last updated” date above. If you are concerned about how your information is used, then bookmark this page and read this Privacy Policy periodically. Your continued use of the Service after changes to the Privacy Policy constitutes your acceptance of the new terms of the Privacy Policy.
HOW TO CONTACT US
SpaPerks LLC is responsible for the processing of your personal information.
If you have any questions or comments regarding this Privacy Policy, you may contact us by email at support@spaperks.com