California Privacy Policy

PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Last Updated: January 1, 2020

This Privacy Policy for California Residents supplements our general Privacy Policy for compliance with the California Consumer Privacy Act ("CCPA"). The CCPA, which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information. Any terms defined in the CCPA have the same meaning when used in this Policy.

Spruz is both a "business" and a "service provider" under the CCPA. The following supplemental privacy policy applies to information we collect in our role as a business - this is when we interact directly with you.

When we act as a service provider (for example, by providing our services to another company that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.

This supplemental privacy policy is effective as of January 1, 2020, shall apply only to residents of California, and may be subject to change. The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosuers in a certain format, as well as to inform you of certain rights you may have.

1. Information we may collect

Categories of PI	Examples
Identifiers	We collect your real name, user name(s), email address, contact number, and information from web browsers, mobile devices and servers, such as Internet Protocol addresses, browser type, language preference, time zone, referring URL, date and time of access, and operating system. We include these in our log files to understand more about visitors to our websites. We do not collect any of the following examples of this category unless you post them on our Services (websites): Social Security Number, driver's license number, passport number, or other similar identifiers. We assign you a unique personal identifier for our internal use. Our service providers may assign you unique personal identifiers.
Categories of personal information described in Section 1798.80(e)	This category overlaps with Category A explained above. We collect your name, and, if you purchase a subscription, payment card information We do not collect any of the following examples of this category unless you post them on our Services: signature, Social Security Number, physical characteristics or description, driver’s license or state identification card number, passport number, bank account number, insurance policy number, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law	We do not request any information in this category. We do not collect any of the following examples of this category unless you post them on our Services: 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).
Commercial information	We keep records of the products and services you have purchased from us.
Biometric information	We do not request any information in this category. We do not collect any of the following examples of this category unless you post them on our Services: 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.
Internet or other electronic network activity information	We collect browsing history, search history, and information on your interaction with our Site and our advertisements.
Geolocation data	We collect your physical location or movements, if you have turned on geolocation on your device. We can also infer your general location by your IP address.
Professional or employment related information	We do not collect current or past job history or performance evaluations, unless you provide this information in the content you post on our Services or if a particular job or profession is required or inferred by the fact of your membership in our Services.
Non-public education information (as per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99))	We do not collect any information in this category unless you post them on our Services.
Inferences drawn from other personal information to create a profile about a consumer.	We do not collect any information in this category.

We collect information about you only if we need the information for some legitimate purpose. Spruz will have information about you only if (a) you have provided the information yourself, (b) Spruz has automatically collected the information, or (c) Spruz has obtained the information from a third party.

2. Purposes for using information

To communicate with you about products and services that you have signed up for or important notices.
To keep you posted on new products and services, offers, promotions and other information relevant to your interests.
To understand how users use our products and services, to monitor and prevent issues, and to improve our products and services.
To ask you to participate in surveys, or to solicit feedback on our products and services.
To set up and maintain your account, and to perform tasks required for providing our services, such as providing website hosting, and backing up and restoring your data.
To provide users with support and to respond to inquiries, including to investigate and address your concerns and monitor and improve our responses.
To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Spruz, Spruz's users, third parties and the public.
To analyze trends, administer our websites, and track visitor navigations on our website to understand what visitors are looking for and to better help them.
To respond to law enforcement requests and as required by applicable law, court order, or government regulations.

3. Who we share your information with

We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

Employees: Employees and independent contractors have access to the information covered in Section 1 on a need-to-know basis. We require all employees and independent contractors of Spruz to follow this Privacy Policy for personal information that we share with them.
Third-party service providers: We may share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Domain registrars: When registering a domain through Spruz from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the ICANN domain registration rules.
Marketplace application developers: When you install or purchase an application developed using Spruz's APIs that is posted on Spruz's online marketplace, your name and email address will be shared with the developer of the application, so that they may engage with you directly as the provider of that application or service. Spruz does not control the use of your personal information by the developers, which will be based on their own privacy policies.

4. Your rights

As a resident of California, you have certain rights under the CCPA:

Right to know: You have the right to know (i) what categories of Personal Information we are collecting about you and for what purposes, (ii) the sources from whom we obtain Personal Information, (iii) what categories of Personal Information we are sharing and for what purposes, and (iv) the categories of third parties to whom we are sharing.
Right to access: You have the right to access the categories of personal information that we hold about you, including the information's source, purposes and period of processing, and the persons to whom the information is shared.
Right to delete: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to data portability: You have the right to receive a copy of your electronic Personal Information in a readily-usable format.
Right to restriction of processing: You have the right to request to restrict the use of your information in certain circumstances.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Exercising your rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by sending an email to us at privacy [at] spruz [dot] com. Only you, or a personal registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consuder request. related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, (ii) 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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

5. Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy [at] spruz [dot] com or write to us at: Spruz Privacy Department, 2708 Foothill Blvd #352, La Crescenta, CA 91214

6. Changes to this Privacy Notice

Spruz reserves 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 Services and update the notice's effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

7. Questions about this Privacy Notice

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or which to exercise your rights under California law, please email us at privacy [at] spruz [dot] com or write to us at: Spruz Privacy Department, 2708 Foothill Blvd #352, La Crescenta, CA 91214.