PRIVACY POLICY

Last updated: July 28, 2023

This privacy notice for Spiral Growth Systems (doing business as Spiral Growth Systems) (“we,” “us,” or “our”) describes how and why we may collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Visit our website at https://spiralgrowthsystems.com, or any website of ours that links to this privacy notice
Engage with us in other related ways, including sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the links or using the Table of Contents below:

What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact.
Learn more in section 1.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services; communicate with you; maintain security and prevent fraud; and comply with the law. We may also process information for other purposes with your consent.
Learn more in section 2.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with third parties.
Learn more in section 4.
How do we keep your information safe?
We use organizational and technical measures to protect your data, though no method is 100% secure.
Learn more in section 8.
What are your privacy rights?
Depending on where you live, you may have rights related to your personal information.
Learn more in section 10.
How do you exercise your rights?
You can submit a data rights request or contact us directly.
See section 10 for details.

Want to learn more? Review the full privacy notice below.

What information do we collect?
How do we process your information?
What legal bases do we rely on to process your personal information?
When and with whom do we share your personal information?
Do we use cookies and other tracking technologies?
Is your information transferred internationally?
How long do we keep your information?
How do we keep your information safe?
Do we collect information from minors?
What are your privacy rights?
Controls for Do‑Not‑Track features
Do California residents have specific privacy rights?
DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us voluntarily. This includes:

Names
Phone numbers
Email addresses

Sensitive Information: We do not process sensitive personal information.

Payment Data: If you make purchases, we may collect your payment instrument number and security code. All payment data is processed and stored by Stripe according to its privacy notice: https://stripe.com/privacy

All personal information must be correct and updated by you.

Information automatically collected

In Short: We collect some information automatically—like your IP address and device/browser details—when you access our Services. This is needed for security, operation, analytics, and reporting. We also use cookies and similar technologies (see our Cookie Notice at https://spiralgrowthsystems.com/cookie-policy/).

We may collect:

Log & Usage Data: IP address, browser type, pages viewed, searches, dates/times, error/crash reports, system activity, and hardware settings.
Device Data: Your device’s IP, application IDs, location, hardware model, operating system, and network provider.
Location Data: Either precise or approximate location via IP or GPS (if enabled). You may disable location settings in your device/browser, but that may affect functionality.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your data to deliver, maintain, and improve Services; communicate with you; secure our platforms; and comply with regulations. We may also use your data for other lawful purposes, such as marketing and ads.

We may process your data to:

Create/manage user accounts (login authentication)
Deliver requested services
Respond to inquiries and support requests
Send administrative information (e.g. policy updates)
Send marketing and promotional communications (opt‑out available)
Deliver targeted advertising (per Cookie Notice)
Protect our Services (security/fraud prevention)
Analyze usage patterns
Measure marketing campaign effectiveness
Safeguard vital personal interests
Evaluate and improve Services, products, marketing, and user experience

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We process data only when we have a valid legal basis:

For EU/UK users (GDPR/UK GDPR), we rely on:

Consent (you can withdraw anytime)
Performance of a contract
Legitimate interests (e.g., fraud detection, marketing)
Legal obligations (e.g., compliance requests)
Vital interests (e.g., safety)

For Canadian users, we rely on:

Express or implied consent
Legal exceptions (e.g., fraud detection, legal compliance, business transactions)

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share your data in specific scenarios, including with:

Ad networks
Communication and collaboration tools
Data storage providers
Finance and accounting tools
Government authorities
Payment processors
Performance monitoring platforms
Retargeting services
Sales and marketing tools
Social networks
Testing platforms
Website hosting/CDN and cloud services
Data analytics providers
Engineering and design tools

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Yes. We use cookies, web beacons, pixels, and similar tools to collect and store information.
You can review and manage preferences through our Cookie Notice: https://spiralgrowthsystems.com/cookie-policy/

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: Yes. Your data may be transferred to and stored in countries outside your own, including the U.S.
If you’re in the EEA/UK, we protect your data using Standard Contractual Clauses per EU guidelines. Copies are available upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your data only as long as needed for the purposes described, unless law requires otherwise.
Once no longer needed, data is deleted, anonymized, or securely archived.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We implement organizational and technical measures to protect your data.
However, no online system is 100% secure—data transmission is at your own risk.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from children under age 18.
If we discover such data, we will deactivate accounts and delete it promptly.
If you become aware of such a case, please contact us at [email protected].

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location (EEA, UK, Canada, California), you may have rights to:

Access, correct, erase, or restrict your data
Data portability
Object to processing
Withdraw consent
Unsubscribe from marketing

To exercise these rights, contact us using the details below.
EEA/UK users also can lodge complaints with their data protection authority.

11. CONTROLS FOR DO‑NOT‑TRACK FEATURES

Most browsers have Do‑Not‑Track settings, but no industry standard exists yet. Therefore, we do not respond to DNT signals. If that changes, we’ll update this notice.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes.

Shine the Light (Cal. Civil Code § 1798.83): California residents may request, once annually, a free list of personal data shared with third parties for marketing.
Under‑18 California users: May request removal of their public content by contacting us with email and proof of residence; we will remove it from public view but backups may remain.

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers
Example: Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
Collected: YES

B. Personal information categories listed in the California Customer Records statute
Example: Name, contact information, education, employment, employment history, and financial information.
Collected: YES

C. Protected classification characteristics under California or federal law
Example: Gender and date of birth.
Collected: NO

D. Commercial information
Example: Transaction information, purchase history, financial details, and payment information.
Collected: NO

E. Biometric information
Example: Fingerprints and voiceprints.
Collected: NO

F. Internet or other similar network activity
Example: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
Collected: NO

G. Geolocation data
Example: Device location.
Collected: NO

H. Audio, electronic, visual, thermal, olfactory, or similar information
Example: Images and audio, video, or call recordings created in connection with our business activities.
Collected: NO

I. Professional or employment-related information
Example: Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
Collected: NO

Use and Retention of Personal Information

We will use and retain the collected personal information as needed to provide the Services or for:

Category A: As long as the user has an account with us.
Category B: As long as the user has an account with us.

We may also collect other personal information outside of these categories when you interact with us in person, online, by phone, or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.

How Do We Use and Share Your Personal Information?

Spiral Growth Systems collects and shares your personal information through:

Targeting cookies / Marketing cookies
Social media cookies
Beacons / Pixels / Tags

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice:
https://spiralgrowthsystems.com/cookie-policy/

You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the “Do Not Sell or Share My Personal Information” link on our homepage.

You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.

If you use an authorized agent to exercise your right to opt out, we may deny a request if the agent does not submit proof that they have been validly authorized to act on your behalf.

Will Your Information Be Shared With Anyone Else?

We may disclose your personal information to our service providers pursuant to written contracts. Each service provider processes information on our behalf and follows strict privacy protection obligations as mandated by the CCPA.

We may also use your personal information for our own business purposes, such as internal research for technological development and demonstration. This is not considered “selling” your personal information.

Personal Information Disclosed to Third Parties in the Last 12 Months

Spiral Growth Systems has disclosed the following categories of personal information to third parties for business or commercial purposes in the preceding twelve (12) months:

Category A: Identifiers, such as real name, alias, postal address, phone number, unique personal identifier, online identifier, IP address, email, and account name.
Category B: Personal information as defined in the California Customer Records law, such as name, contact info, education, employment, employment history, and financial information.

The categories of third parties to whom we disclosed personal information for business purposes can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

Categories of Third Parties with Whom We Sold or Shared Personal Information

Ad Networks
Data Analytics Services
Retargeting Platforms
Social Networks

Your Rights With Respect to Your Personal Data

Right to Request Deletion: You may ask for deletion of your personal information, subject to certain legal exceptions.
Right to Be Informed: You have the right to know if we collect and use your personal information; what categories we collect; purposes for use; if we sell or share it; categories sold or shared; categories of third parties receiving it; business purposes; and specific data collected.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information: We do not process sensitive personal information.

Verification Process

To process your request, we will verify your identity by matching the information you provide with our records. This may involve contacting you through previously provided communication methods. We only use information necessary for verification and will delete additional data once verification is complete.

Other Privacy Rights

You may object to the processing of your personal information.
You may request correction or restriction of your personal data.
You may designate an authorized agent to act on your behalf under the CCPA. Requests from agents without proof of authorization may be denied.

To exercise your rights, contact us at [email protected] or use the contact details below. Complaints are welcome.

13. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes. Residents of Virginia have rights regarding access to and use of personal information under the Virginia Consumer Data Protection Act (CDPA).

Consumer: A natural person resident of Virginia acting only in an individual or household context, not commercial or employment.
Personal Data: Information linked or reasonably linkable to an identified person (excludes de-identified or public data).
Sale of Personal Data: Exchange for monetary consideration.

Spiral Growth Systems has not sold personal data of Virginia residents and will not sell it in the future.

Your rights include:

Right to be informed about data processing
Right to access and correct your personal data
Right to request deletion
Right to obtain a copy of your data previously shared
Right to opt out of processing for targeted ads, sale, or profiling

More info and how to exercise your rights at:
https://spiralgrowthsystems.com/cookie-policy/

Contact: [email protected]

Verification Process for Virginia Residents

We may request additional information to verify identity or authorized agents. We will respond within 45 days, with a possible 45-day extension. You have the right to appeal decisions.

14. DO WE MAKE UPDATES TO THIS NOTICE?

Yes. We update this notice as needed to comply with laws. Updates will be marked by a “Revised” date and will be effective upon posting. Significant changes may be notified via prominent posting or direct notification. We encourage frequent review.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Data Protection Officer: Christopher East
Email: [email protected]
Phone: 310-869-6170
Address:
Spiral Growth Systems
30 N Gould St Suite R
Sheridan, WY 82801
United States

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on your country’s laws, you may request access, changes, or deletion of your personal information. To do so, submit a data subject access request.