ChatSpin Privacy Policy

Last Updated: March 26, 2024

Introduction

Social Media Ventures LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website chatspin.com and, if we offer a mobile application, when you download, install, access, or use the mobile application (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.

  • In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any nonparty (including our affiliates and subsidiaries); or

  • Any nonparty (including our affiliates and subsidiaries), including through any application or content (including advertising) that might link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you disagree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. We may change this policy on one or more occasions (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Individuals Under the Age of 18

Our Website is not intended for individuals under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you might use. If we learn we have collected or received personal information from an individual under 18, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us at privacy@chatspin.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • Identity Data includes username or similar identifier and gender.

  • Contact Data includes email address and telephone number.

  • Financial Data includes payment card details. We store only very limited, if any, Financial Data. Otherwise, all Financial Data is stored by our payment processor, and you are encouraged to review its privacy policy and contact it directly for responses to your questions.

  • Transaction Data includes details about payments from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, ISP name, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website, including your webcam and microphone.

  • Device Data includes the type of mobile device (“Device”) you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.

  • Profile Data includes your username and password, including password hints and other information for authentication and account access, purchases made by you, your interests, preferences, feedback, and survey responses.

  • Usage Data includes information about how you use our Website, products, and services.

  • Location Data includes your current location disclosed by IP address and information about proxies.

  • Third-Party Login Data includes your email address and password if you choose to link your third-party account with us to facilitate account creation and logon process.

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through the Website. Information collected automatically might include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From nonparties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided when registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

  • Your search queries on the Website.

You also may provide information to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or nonparties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you might be able to set certain privacy settings for that information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across nonparty websites or other online services (behavioral tracking). Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit https://fpf.org/thank-you-for-visiting-allaboutdnt-com/

The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection might include:

  • Cookies (or browser or mobile cookies). A cookie is a small file placed on your computer’s hard drive or smartphone. You may refuse to accept cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting you might be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

  • Web Beacons. Pages of our Website and our emails might contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Nonparty Use of Cookies and Other Tracking Technologies

Our Website uses Google Remarketing, a service of Google LLC, to advertise on nonparty websites to you after you visit our Website. We and Google use cookies to inform, optimize, and serve ads based on your past visits to our Website. Cookies and similar technologies are also used to perform the analysis of website usage as a basis for creating interest-based advertisements. The data arising in this context can be transmitted by Google to a server in the US for evaluation and stored there. If you use a Google Account, depending on the settings in your Google Account, Google may link your Google web and app browsing history to your Google Account and use information from your Google Account to personalize ads. If you don’t want this association with your Google Account, you’ll need to log out of Google before you can access our contact page.

We do not control these nonparties’ tracking technologies or how they might be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To identify you as a visitor or user on our Website.

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To provide you with notices about your subscription, including expiration and renewal notices.

  • To determine your current location.

  • To facilitate account creation and logon process if you choose to register or log in to our Website using your third-party account.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide through it.

  • To allow you to participate in interactive features on our Website, including live video chat.

  • To ensure that we present our Website content in the most effective manner for you and for your computer or device.

  • To administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.

  • To use data analytics to improve our Website, products or services, marketing, or customer relationships and experiences.

  • To protect our Website, employees, or operations.

  • To assist law enforcement and respond to subpoenas.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

AI Training and Data Security


Collection and Use of Screenshots for AI Training

To continuously improve our AI systems and provide you with a more effective and personalized user experience, we collect small samples of random screenshots. These screenshots are used for training our AI algorithms only.

Data Security and Anonymity

We prioritize your privacy and data security:

  • Encryption: All screenshots are encrypted to ensure the highest level of data security.

  • Anonymity: We take careful steps to ensure that these screenshots do not contain any personally identifiable information or account details. Before storage, each screenshot undergoes a process to remove any potential personal or sensitive information.

  • Indefinite Storage: These encrypted and anonymized screenshots are stored indefinitely to continuously enhance our AI’s learning and development process.

By using our services, you consent to the collection, use, and storage of data as described in this section. We are committed to maintaining transparency about our data practices and ensuring the privacy and security of your information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.

  • To contractors, service providers, and other nonparties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. For example, we use Google Analytics to help us understand how our users use our Website (you can read more about how Google uses your personal information here: https://policies.google.com/privacy).

  • To a buyer or other successor if a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.

  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

The categories of personal information we may disclose include:

  • Identity Data;

  • Contact Data;

  • Financial Data;

  • Transactional Data;

  • Technical Data;

  • Device Data; and

  • Profile Data.

Consent to Personal Information Transfer

We are based in the United States of America. We may process, store, and transfer the personal information we collect, in and to a country outside your own, with different privacy laws that might or might not be as comprehensive as your own.

By submitting your personal information or engaging with our Website, you hereby consent to this transfer, storing, or processing, including transferring your information across international boundaries to jurisdictions anywhere in the world as permitted by law.

If you are a Canadian resident or otherwise located in Canada, please note that personal information transfers outside of Canada might result in your information becoming accessible to foreign jurisdiction’s law enforcement or other authorities.

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), please note that your information will be transferred outside of those areas, including to the United States. Nevertheless, whenever we transfer your personal information out of the EEA, Switzerland, or UK, we will use reasonable efforts to ensure a similar degree of protection is afforded to it by ensuring that the recipient nonparty agrees to contractual clauses or other appropriate safeguards.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website might become inaccessible or not function properly.

  • Location Information. You can choose whether or not to allow the Website to collect and use real-time information about your Device’s location through the Device’s privacy settings. If you block the use of location information, some parts of the Website may become inaccessible or not function properly.

You can opt out of Google Analytics for Displaying Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page at http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser, which is available at https://tools.google.com/dlpage/gaoptout. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on Google’s privacy practices, please visit https://policies.google.com/privacy.

Residents of certain jurisdictions, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia, the European Economic Area, and the United Kingdom might have additional personal information rights and choices. Please see Your State Privacy Rights and Your EEA/UK Privacy Rights for more information.

Accessing and Correcting Your Information

If you have registered, you can review and change your personal information by logging into the Website and visiting your account profile page. Otherwise, you may email us at privacy@chatspin.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We might not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain jurisdictions, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia, the European Economic Area, and the United Kingdom might have additional personal information rights and choices. Please see Your State Privacy Rights and Your EEA/UK Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their personal information.

  • Access and delete certain personal information.

  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).

  • Data portability.

  • Opt-out of personal data processing for:

    • targeted advertising (excluding Iowa);

    • sales; or

    • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

  • Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights might vary by state. To exercise any of these rights please email us at privacy@chatspin.com. To appeal a decision regarding a consumer rights request email us at privacy@chatspin.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: privacy@chatspin.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Your EEA/UK Privacy Rights

If you live in the EEA or the UK, the following terms apply to you.

Legal Basis for Processing

We may process your personal data because you have given us permission to do so (for example, by sending data through our Website’s contact or signup forms), because the processing is in our legitimate interests and it is not overridden by your rights, or because we need to process your personal data to perform a contract with you or comply with the law.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your erasure request for specific legal reasons that will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

  • Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy; (2) where our use of the data is unlawful, but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (4) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@chatspin.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us on our secure servers behind firewalls. Any payment transactions and screenshots will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like chat rooms. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information through the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

Our policy is to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Social Media Ventures LLC
30 N Gould St Ste 3685 Sheridan, WY 82801

privacy@chatspin.com

ChatSpin Privacy Notice for California Residents

This privacy notice for California residents supplements the information contained in ChatSpin’s privacy policy and applies solely to all visitors, users, and others who reside in California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from its consumers within the last 12 months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

NO

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

Our Website obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.

  • Indirectly from you. For example, from observing your actions on our Website.

  • From third parties. For example, from our business partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment. We may also save your information to facilitate new product orders.

  • To provide, support, personalize, and develop our Website, products, and services.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise stated in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.

  • Internet cookie data recipients, like Google Analytics.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.

    Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

  • Internet cookie data recipients, like Google Analytics.

Sales of Personal Information

In the preceding 12 months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make that request, please send an email to privacy@chatspin.com.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Social Media Ventures LLC collects and uses your information described below and in the Privacy Policy, your choices and rights regarding that use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

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