We at Sparemin, Inc. (“Sparemin,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you 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 our Platform. By visiting our Platform, Visitors and Registered Users are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Service.

The Information We Collect and/or Receive

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

1. Personal Information

When you sign up to become a Registered User, you will be required to provide us with personal information about yourself, such as your name, e-mail address, and Credentials. If you contact us, you will need to provide your name and e-mail address. Registered Users may also be required provide identifiable information in order to access certain features of the Platform, to initiate or participate in a Call, or otherwise in the course of using the Platform. All information that we receive under this section is collectively called “Personal Information.” We do not collect any Personal Information from Visitors or Registered Users when they use the Platform, unless they provide such information voluntarily.

2. Call Information

The Platform is designed to connect individual Influencers and Callers, as well as to help Influencers connect with their fans throughout the Platform. 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. Geolocational Information

Certain features and functionalities of the Platform are 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 geolocational information from your mobile device or wireless carrier and/or certain third-party service providers. Such information is collectively called the “Geolocational Information.” Collection of such Geolocational Information occurs only when the Platform is running on your mobile device. You may decline to allow us to collect such Geolocational 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 Platform, we may automatically collect certain information when Visitors and Registered Users access and use the Platform. 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 Platform 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 Platform 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 Other Information and to enhance your experience using the Platform. 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 Platform 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 Platforms. By submitting your Credentials, you authorize us to use those Credentials to communicate with and receive information from the third-party platform to which those Credentials relate (including, without limitation, a list of your followers or connections, your profile information, or information regarding your activity on such third-party platform).

The Information Collected by or Through Third-Party Advertising Companies

You authorize us to share Other Information about your activity on the Platform with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Platform 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 a user to a given site.

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 Platform, products, and services; to process transactions you request; 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 Platform.

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

We may share the Information concerning our Registered Users with our resellers, distributors, and sales representatives, which may use such Information to help inform Registered 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 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 Visitors, Registered Users, Platform, 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 Platform and/or such products and services. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe the Platform and these products and services to current and prospective business partners and to other third parties for other lawful purposes.

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.

Accessing and Modifying Information and Communication Preferences

Registered Users may access, remove, review, and/or make changes to their Personal Information through the Platform or by contacting us via email at info@Sparemin.com. In 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.

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 Platform 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 Platform 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 Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Platforms

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

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Platform. 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 Platform 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.

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

85 Broad Street, 18^th Floor

NY, NY 10004

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 Platform. By accessing the Platform 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 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.