SPAREMIN PRIVACY POLICY FOR SPAREMIN MOBILE APP AND HEADLINER SOFTWARE
Last Updated January 4, 2018

 

We at Sparemin, Inc. (“Sparemin,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that as an end user of our products and services, you (“you,”“your” or “end user”) care about how your information is used and shared.  This Privacy Policy relates to the information collection and use practices of Sparemin in connection with (1) our conversation and social connectivity service currently called “SpareMin Mobile App” (“Social Platform”), and (2) our video software-as-a-service currently called “Headliner” (“Software”).  The Social Platform and the Software are both made available through the website located at sparemin.com (including any successor websites) (“Site”) and/or via a mobile application(s) (“Mobile App”).  The Social Platform, Software, Site and Mobile App are collectively referred to herein as the “Service”. 

 

The Information We Collect and/or Receive

In the course of operating the Service, Sparemin will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

 

1.           Personal Information

While you can browse through certain publicly-available information in the Service without registering for an account, in order to use all of the features and functionality of the Social Platform and the Software, you will be required to create an account with us (“Account”).  You may be asked to provide certain registration details or other information, to enable you to create an end user Account and to help us provide the Service to you, including personal information about yourself, such as your name, e-mail address, credit card information (for paid, premium portions of the Service) and certain information that will assist us in authenticating your identity when you log-into the Service in the future.  You may also be required provide identifiable information in order to access certain features of the Service, to initiate or participate in a Call, or otherwise in the course of using the Service. 

 

Please be advised that if you contact us, you will need to provide your name and e-mail address to enable us to respond to any requests or questions.  All information that personally identifies you is collectively called “Personal Information” in this Privacy Policy. We do not collect any Personal Information from you of the Service unless you provide to us voluntarily (including by way of a Social Media Site).

2.           Call Information

The Social Platform is a conversation Service for the social web, which allows “Callers” and “Influencers” to connect through short, recorded VoIP calls (each, a “Call”).  “Callers” end users with an Account who request and participate in Calls with selected Influencers, and “Influencers” are end users with an Account who accept and participate in Calls with Callers. The Service is designed to connect individual Influencers and Callers, as well as to help Influencers connect with their fans throughout the Service. By participating in a Call, you are giving permission for us to record the Call and for the Influencer to share the recording of the Call in any manner that is consistent with this Agreement. Calls are not intended to be private, and you should think carefully about the information you disclose on a Call. Sparemin may also transcribe Calls and store, process, or crawl any such transcriptions for any data or information contained in the Call.

3.           Video Software Use Information.

In connection with your use of the Video Software, the Service will collect data on what audio, images, and text are used within the video.  Sparemin may also store, process, and collect information on how the video software is used including mouse movement, clicks, and keyboard entry.

 

4.           Geolocation Information

Certain features and functionalities of the Service may only be used based on your location.  In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device or wireless carrier and/or certain third-party service providers.  Such information is collectively called the “Geolocation Information.”  Collection of such Geolocation Information occurs only when the Service is running on your mobile device.  You may decline to allow us to collect such Geolocation Information, in which case Sparemin will not be able to provide certain features or functionalities to you.

4.         Other Information.

In addition to the Personal Information, we may collect or receive additional information (collectively, the “Other Information”).  Such Other Information may include:

            a.         From Your Activity.  In an ongoing effort to improve the Service, we may automatically collect certain information when end users access and use the Service.  Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Service end users visit, log files, and similar information and data.

            b.         From Cookies.  We collect information using “cookie” technology.  Cookies are small packets of data that a Service stores on your computer’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect statistics in the aggregate about end user behavior, to help you access the Service and to enhance your experience using it.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer.  Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  However, if you decide not to accept cookies from us, the Service may not function properly.

 

            c.         From You.  You may voluntarily provide us additional information about yourself that does not identify you personally, such as your gender, country, product and service preferences, and other information (including, without limitation, User Content and any information provided during a Call).

 

            d.        From Third-Party Services.  By submitting your certain information that will assist us in authenticating your identity when you log-into the Service, you authorize us to use that information to communicate with and receive information from the third-party platform to which such information relates (including, without limitation, a list of your followers or connections, your profile information, or information regarding your activity on such third-party platform). Third-party social media buttons displayed within the Service may record your IP address, browser type and language, access time and referring website addresses.  When you are logged in to those social media websites, they also may link this collected information with your profile information on that website. We do not control these third party tracking technologies.

If you connect to the Service using credentials from a third-party social media application such as Facebook, Instagram or Twitter (e.g., “Login with Facebook,” or “Sign In with Twitter”) (each, a “Social Media Site”), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information made available on or through your Social Media Site account, including your name, profile picture, country, hometown, email address, date of birth, gender, and networks. The Service will not store end user names or passwords from any Social Media Site or use any “friend” or “follower” data from any Social Media Site.

The Information Collected by or Through Third-Party Advertising Companies

We may tailor our advertisements to certain end users based on the unidentified end user data and related information. Also, we may receive information on unidentified end users’ movements on other websites to tailor advertisements to them on our Site and, likewise, provide unidentified end user information to service providers, such as an ad agency, who places our advertisements on other websites to market to these end users that visit them. 

You authorize us to share Other Information about your activity on the Service with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Service and elsewhere.  These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes.  Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings an end user to a given site.

You can opt out of this tracking by accessing the link below. You will need to invoke these opt-out procedures on each computer you use. If you opt out, you may still see SpareMin advertisements on other websites you visit, but these ads are not end-user specific and are not placed because of your past visits to our Site.

To opt out of advertising which utilizes cookies, access the following link:

http://www.networkadvertising.org/choices/

·       All major Internet browsers allow you to control cookies. You can learn more about adjusting browser controls at the following website: http://www.aboutcookies.org. (Note that SpareMin does not control this website and is not responsible for its content. It is provided as information only. For the most current browser-specific information, please consult your browser’s manufacturer).

Do Not Track

We do not track our customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

How We Use and Share the Information  

You authorize us to use the Personal Information and the Other Information (collectively, the “Information”) to provide and improve our Service, products, and services; to process transactions you request; to contact you to discuss the support, renewal and purchase of our products and services (including by our service providers on our behalf), to inform you about our products and services and those of our promotional partners; and to bring you customized content (such as newsletters) based on your activity on the Service.

 

You also authorize us to use and/or share Information as described below.

 

·       We may share the Information concerning our end users with our resellers, distributors, and sales representatives, which may use such Information to help inform end users about our products and services.

 

·       We may, from time to time, share Information with other companies, which may provide you information about the products and services they or their partners offer.  However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.

 

·       We will access, use, and share the Information as required to fulfill our contractual obligations to you and to address your questions or requests regarding our products, services, and/or support.

 

·       We may employ other companies and individuals, such as service providers, to perform functions on our behalf.  Examples may include providing technical assistance, recruiting services, order fulfillment, customer service, and marketing assistance.  These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

 

·       In an ongoing effort to better understand our end users, and our Service, products and services and those of our promotional partners, we may analyze certain Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Service and/or such products and services.  This aggregate information does not identify you personally.  We may also disclose aggregated end-user statistics in order to describe the Service and these products and services to current and prospective business partners and to other third parties for other lawful purposes.

 

·       The Service may use “social plug-ins” which are provided and operated by Social Media Sites (such as Facebook, Instagram and Twitter) to enable you to share certain information from the Service on the applicable Social Media Sites. If you are logged into your account with a Social Media Site, it may be able to link information about your visit to our Service to your account or profile with the Social Media Site. Similarly, your interactions with the social plug-in may be recorded by the Social Media Site. We will display the information to be shared with the Social Media Site to you prior to submitting it to the Social Media Site for sharing. You understand and agree that that such information may be attributed to your account on the Social Media Site and may be published thereon

·       You understand and agree that any Social Media Site’s or any other third-party application’s use of information collected from you (or as authorized by you) is governed by the Social Media Site’s or third-party application’s privacy policies and your settings on the relevant service, and our use of such information is governed by this Privacy Policy and your Service account settings. 

 

·       We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

 

·       As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

 

·       To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Sparemin or others, or to prevent any other harm to yourself or others. 

How We Protect the Information

We take reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Service may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Service and its servers are operated in the United States and elsewhere.  Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to use the Service, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

 External Services

The Service may contain links to third-party Services.  Sparemin has no control over the privacy practices or the content of these Services.  As such, we are not responsible for the content or the privacy policies of those third-party Services.  You should check the applicable third-party privacy policy and terms of use when visiting any other Services.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Service.  If you are under 13, please do not give us any Personal Information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Service without their permission.  If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

Accessing and Modifying Information and Communication Preferences

End users may access, remove, review, and/or make changes to their Personal Information through the Service or by contacting us via email at info@Sparemin.comIn addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Sparemin marketing e-mail.  We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Sparemin may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes.  If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to info@Sparemin.com with “PRIVACY POLICY” in the subject line or write to us at:

Sparemin Inc. – Attn: Privacy Policy

1204 Broadway, 4th Floor

NY, NY 10001

 

In addition, as of the date of this Privacy Policy, Sparemin does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

 

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time.  Any such changes will be posted on the Service.  By accessing the Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.  Please refer back to this Privacy Policy on a regular basis.

 

How to Update or Correct Personal Information

If you would like to update, delete or correct any Personal Information in our records, please contact us via email.

 

How to Contact Us 

If you have questions about this Privacy Policy, please contact Sparemin via e-mail at info@Sparemin.com with “PRIVACY POLICY” in the subject line.