SPAREMIN PRIVACY POLICY FOR HEADLINER DISCO SOFTWARE
Last Updated November 8, 2021

 

We at Sparemin, Inc. (“Sparemin,” “we,” “us,” or “our”) have created this privacy policy (“Privacy Policy”) to explain how we collect, process, use, and disclose information that we obtain through our website, www.headliner.app/disco including any subdomains and successor websites (“Sites”), our podcast recommendation software, our reporting site, and podcast destination site, plus any software integrated into 3rd party websites (collectively “Services”).

In the course of operating the Services, Sparemin will collect (and/or receive) the following types of information (“Personal Information” or “Personal Data“, collectively, the “Information”). You authorize us to collect and/or receive such Information.

We may use Information collected through the Sites and Services in various ways, depending on whether you are a publisher, advertiser, or other entity that has a contract with us (a “Customer“) or a visitor to our Customers’ websites, mobile, and other apps who interacts with our Services (“End User“).  When differences arise between Customer and End User in the following sections, each will be labeled as such, for any section without labeling, it applies to both Customer and End User.

1.         Personal Information

Customer

In order to use the reporting and control features and functionality of the Software, you will be required to register for an account with us.  You may be asked to provide certain registration details or other information, to enable you to create a user account and to help us provide the Service to you (“Account”).  You will be asked to provide certain registration details or other information, to enable you to create an end user Account and to help us provide the Service to you, including personal information about yourself, such as your name, e-mail address and certain information that will assist us in authenticating your identity when you log-into the Service in the future.  You may also be required provide identifiable information in order to access certain features of the Service (e.g., support).  If you choose to pay for the service, you may need to pay for the service through Stripe, where we will gain access to your Stripe ID, but will not receive any/all credit card information.

Please be advised that if you contact us, you will need to provide your name and e-mail address to enable us to respond to any requests or questions.  All information that personally identifies you is collectively called “Personal Information” in this Privacy Policy. We do not collect any Personal Information from you of the Service unless you provide to us voluntarily.

End User

We automatically collect End User Information when Users interact with our Services.  Sparemin only collects pseudonymized data, without ever knowing your name, email, or any other identifiable data unless you directly contact us with that information.  User Information that we collect includes, but is not limited to, Information about a User’s device and operating system, IP address, the web pages accessed by Users within our Customers’ websites, the link that led a User to a Customer’s website, the dates and times a User accesses a Customers’ website.

2.        Software Use Information

Customer

We use the Information to provide and improve the service.  We also use info like email addresses to communicate with you about the service.  Finally, we may use the information to tailor marketing information.

End User

We use the Information to provide and improve the service.  We also use the Information to better recommend podcasts to you.  This is done by understanding your click behavior only on our own software.

3.        Geolocation Information

Certain features and functionalities of the Service may only be used based on location.  In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device or wireless carrier and/or certain third-party service providers.  Such information is collectively called the “Geolocation Information.”  Collection of such Geolocation Information occurs both when the Service is running on your mobile device and your desktop device.  You may decline to allow us to collect such Geolocation 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:

  1. From Your Activity.  In an ongoing effort to improve the Service, we may automatically collect certain information when end users access and use the Service.  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 Service end users visit, log files, and similar information and data.

  1. From Cookies.  For the avoidance of doubt, we do not collect information using “cookie” technology on 3rd party websites.  We do collect information using “cookie” technology on our own sites.  Cookies are small packets of data that a Service 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 statistics in the aggregate about end user behavior, to help you access the Service and to enhance your experience using it.  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 Service may not function properly.

  1. 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 any content you access or upload to the Service).

  1. From Third-Party Services.  By submitting your certain information that will assist us in authenticating your identity when you log-into the Service, you authorize us to use that information to communicate with and receive information from the third-party platform to which such information relates (including your profile information, or information regarding your activity on such third-party platform). Third-party social media buttons displayed within the Service may record your IP address, browser type and language, access time and referring website addresses.  When you are logged in to those social media websites, they also may link this collected information with your profile information on that website. We do not control these third party tracking technologies.

If you connect to the Service using credentials from a third-party social media application such as Facebook or Google (e.g., “Login with Facebook,” or “Sign In with Google”) (each, a “Social Media Site”), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information made available on or through your Social Media Site account, including your name, profile picture, country, hometown, email address. The Service will not store end user names or passwords from any Social Media Site or use any “friend” or “follower” data from any Social Media Site.

Do Not Track

We do not track our customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals.

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 Service, products, and services; to process transactions you request; to contact you to discuss the support, renewal of our products and services (including by our service providers on our behalf).  Unless authorized and accepted by you, we will not inform you about our products and services and those of our promotional partners and we will not bring you customized content (such as newsletters) based on your activity on the Service.  We will contact you via email for service related notices though.

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

 

 

 

 

 

 

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

 External Services

The Service may contain links to third-party Services (e.g., YouTube (Google), Facebook, Twitter, Instagram, and LinkedIn).  Sparemin has no control over the privacy practices or the content of these Services.  As such, we are not responsible for the content or the privacy policies of those third-party Services.  You should check the applicable third-party privacy policy and terms of use when visiting any other Services via the links provided and on their respective web properties.  By using any of these services you are agreeing to be bound by their respective privacy policies.

Children

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

Accessing and Modifying Information and Communication Preferences

End users may access, remove, review, and/or make changes to their Personal Information through the Service 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.

Retention

Your information will be stored on our servers for a maximum of 24 months.  If you would like deletion of your data for any reason, contact us via email at info@Sparemin.com.  We will use commercially reasonable efforts to process such requests in a timely manner.

California Residents

Effective as of January 1, 2020

If you are a California resident, the processing of some information may be subject to the California Consumer Privacy Acct (“CCPA”) and other applicable California state privacy laws.  This Notice does not apply to employment related personal information collected from California based employees, job applicants, contractors, or similar individuals.

We have collected the following categories of personal information within the last twelve (12) months:

Collected:

NOT Collected

Sales of Personal Information

Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity ever (including that we do not “sell” the personal information of minors under 16 years of age).  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.  SpareMin does not share your information with 3rd parties for direct marketing purposes so there is no need to contact us to opt-out of this.  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.

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, we will disclose the same to you.

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, we will delete your personal information from our records, unless an exception applies.

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 sending an e-mail to info@Sparemin.com with “PRIVACY POLICY” in the subject line or writing us at:

Sparemin Inc. – Attn: Privacy Policy

121 E 23rd St, #12C,

New York, NY 10010

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

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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.

 

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 Service.  By accessing the Service 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 Update or Correct Personal Information

If you would like to update, delete or correct any Personal Information in our records, please contact us via email.

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.