This Privacy Notice (“Notice”) applies to personal data Spirence LLC and affiliates (collectively, “Spirence,” “we,” “us,” or “our”) collects. This Notice also covers rights and choices related to your personal data.
We collect data about you in different ways. For example, we collect data:
The following are a few examples of our collection and use of data:
| Context | Types of Personal data | Primary Purpose and Legal Basis |
| Account Registration | We collect your name and contact information when you make an account. We also collect data on the actions that you perform while logged in. | We have a legitimate interest in providing account related functionalities to users. Accounts can offer easy checkout, saved preferences, and purchase history. |
| Client Information | We collect the name and contact information of our clients and their employees with whom we may interact. | We have a legitimate interest in contacting our clients and communicating with them about business activities such as projects, services, and billing. |
| Your Use of Our Website | We use technology (e.g., a cookie or a pixel) to learn how you engage with our websites. This may include which links you click or what you type into our online forms. We may also track your IP address, the website that referred you to us, and data about your device. | We have a legitimate interest in making our website operate. We also use it to understand how you interact with our websites, gather analytics, improve our websites, and learn your preferences. We may also use this data to help detect and prevent fraud. Where required by law, we base the use of technologies upon consent. |
| Technology on Our Website for Targeted Advertising | We may let third parties place tracking technology on our websites (e.g., a cookie or a pixel). The third party might also collect data over time and across other websites. Among other things, they may use this data to serve ads tailored to your interests, which may include ads about our products or services. | Where required by law, we base the use of third-party tracking technologies upon consent. Please see your browser settings for more information about managing cookies. |
| Feedback/Support | If you provide feedback or contact us for support, we collect your name and email, as well as other content that you share to reply. | We have a legitimate interest in receiving and acting upon feedback. |
| Mailing List | When you sign up for our mailing lists, we collect your email or postal address. | We have a legitimate interest in sharing information about our products and services. Where required by law we will ask for your consent before communicating with you. |
| Order Placement | We collect your name, billing, shipping, and email addresses, phone number, and credit or debit card information when you place an order. | We use your information to perform our contract to provide services. |
| Partner Promotion | We collect data that you provide as part of co-branded promotions with other companies. | We have a legitimate interest in fulfilling our promotions. |
| Surveys | We collect data you share through surveys. If a survey is offered by a third-party service provider, the third party’s privacy notice applies to the collection, use, and disclosure of your data. | We have a legitimate interest in understanding your opinions. |
We also use data to:
The sections above describe our main purposes in collecting your data, but often we have multiple purposes. For instance, if you make an online purchase, we may collect your information to perform our contract with you. We also have a legitimate interest in maintaining that data so that we can easily address questions about an order. As a result, our collection and processing of your data is based in different contexts on your consent, our need to perform a contract, our legal obligations, and/or our legitimate interest in conducting our business.
In addition to the specific situations discussed elsewhere in this Notice we may share personal data in the following situations:
Some jurisdictions require us to disclose whether the following categories of personal data are collected, shared with third parties for a “business purpose,” or “sold,” or transferred for “valuable consideration.” The table below indicates the categories of personal data we collect and transfer in a variety of contexts. We do not “sell” your personal data for money.
| Category of Personal Data | Category of Recipients | ||
| Disclosures for a Business Purpose | Sharing for Targeted Advertising | Sales | |
| Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers. | – Affiliates or subsidiaries – Business partners – Data analytics providers – Internet service providers – Operating systems and platforms – Other Service Providers – Payment processors and financial institutions – Professional services organizations, this may include auditors and law firms – Social networks | Advertising networks | N/A. |
| Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | – Internet service providers – Operating systems and platforms – Other Service Providers – Payment processors and financial institutions – Professional services organizations, this may include auditors and law firms – Social networks | N/A. | N/A. |
| Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, app, or ad. | – Data analytics providers – Internet service providers – Operating systems and platforms | Advertising networks | N/A. |
| Geolocation data – this refers to non-precise geolocation information such as your city, state, or neighborhood. | – Data analytics providers – Internet service providers – Operating systems and platforms | Advertising networks | N/A. |
| Inferences drawn from any of the information listed above | – Affiliates or subsidiaries – Business partners – Data analytics providers – Operating systems and platforms – Other Service Providers – Professional services organizations, this may include auditors and law firms – Social networks | N/A. | N/A. |
| Additional categories of personal data described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number. | – Affiliates or subsidiaries – Business partners – Data analytics providers – Data brokersInternet service providers – Operating systems and platforms – Other Service Providers – Professional services organizations, this may include auditors and law firms – Social networks | N/A. | N/A. |
Some jurisdictions give you a right to make the following choices about your personal data:
Not all the rights above are absolute, and they do not apply in all circumstances. We may limit or deny some requests because the law permits or requires us to. We will not discriminate against individuals who exercise their privacy rights under applicable law.
Submitting Requests
You may exercise the above rights by contacting us via the contact information below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”
As required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name. We may also ask you to share a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal data about you in our files.
In some circumstances, you may designate an authorized agent to exercise certain privacy rights on your behalf. To do so, you must (1) provide that authorized agent written, signed, and notarized permission to submit such request, and (2) verify your own identity directly with us.
If you are submitting a request on behalf of another person, you must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. That individual can request reasonable reimbursement for the cost of such notarization. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.
No method of internet transmission or electronic storage is fully secure. While we use reasonable efforts to protect your personal data, we cannot guarantee its security. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits.
Some of our websites permit you to make a password protected account. You are responsible for selecting a unique and complex password and keeping it confidential. You are responsible for any access to or use of your account by someone who has obtained your password, whether or not you approved of such access or use. Notify us of unauthorized use of your password or account immediately.
We keep your personal data for only as long as necessary to fulfil the purposes in this Notice unless a longer retention period is required or permitted by law. This includes the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data. We also weigh the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we obtained the data and whether we can meet those purposes through other means, as well as applicable legal requirements.
As we operate in various countries internationally, your data may be processed in a country with less stringent privacy laws than the laws in the country that you reside. Where possible, we treat personal data using the same privacy principles that guide the law of the country in which we first receive your data. By submitting your personal data to us you acknowledge that we may transfer, store, and process your data in a country other than your country of residence including, but not limited to, the United States. For more information on our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another, contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.
We may provide links to websites and other third-party content or services that we do not own or operate. We have no control over the privacy practices of websites or services we do not own. For details about such third parties’ privacy practices, see their privacy notices.
We may change our Notice and privacy practices. New notices will be published on our website. If changes are material, the Notice that was in place when you submitted personal data to us will generally govern that data unless you consent to the new Notice. Our Notice shows “effective” and “last updated” dates below. The effective date is the date the current version took effect. The last updated date is the date the current version was last substantively changed.
Our websites and online services are not meant for children under 13 years old, and we do not knowingly collect personal data from children under age 16 without parental consent. Children under 13 should not give us their personal data.
If you have questions, comments, or complaints on our privacy practices, or if you need to access this Notice in a different form due to a disability, please contact us via this link: https://spirencewellness.com/about/contact/. We will try to address your requests and provide you with additional privacy-related information.
If you are not satisfied with our response and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.
California law requires us to disclose the following information on our privacy practices. If you are a California resident, the following disclosures apply to you in addition to the rest of the Notice.
Effective Date:
November, 20 2024
Last Update:
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