This policy applies to information we collect:
It does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from our Website.
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Website or through any of its features or social media links, register on our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].
We do not collect, and do not have access to, your social security number or information about your financial accounts or history via our Website.
We collect several types of information from and about users of our Website, including information:
We collect this information:
The information we collect on or through our Website may include:
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:
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
We use information that we collect about you or that you provide to us, including any personal information:
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may disclose aggregated information about our users without restriction.
We may also disclose your personal information and/or technology usage information:
In addition to the policies described herein regarding our collection and use of your personal information (and the other information elsewhere described herein, if you enroll in the Spire Loyalty Program (“Spire Loyalty”), the Company and Fidel, its third party Service Provider, will collect and monitor information regarding the transactions that you make on Linked Cards, as described in the Spire Loyalty Terms and Conditions. This information is referred to as “transactional information” and is treated differently than your personal information and other information described herein. For example, if you register a payment card as a “Linked Card” in connection with transaction monitoring, you authorize us to share your payment card information with the “Payment Networks” so the applicable Payment Network(s) is or are informed of the registration of the Linked Card as a part of Spire Loyalty. You authorize the applicable Payment Network(s) to monitor transactions on your Linked Card(s) to identify “Eligible Transactions” in order to determine whether you have qualified for or earned an offer linked to your Linked Card(s), and for the Payment Network(s) to share such transaction details with us to enable your Linked Card(s) offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the Linked Card(s) at any time by either (a) deleting the Linked Card(s) as Linked Cards or (b) terminating your participation in the Spire Loyalty, in either case in accordance with the Spire Loyalty Terms and Conditions.
Notwithstanding anything to the herein or in the Spire Loyalty Terms and Conditions, the Company and its third party Service Providers (including Fidel Limited) will use transaction information solely as follows: Use transaction data such as transaction amount, transaction time and merchant location to confirm an Eligible Purchase or return to match transactions to confirm whether you qualify for rewards. Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred. For example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction; Provide participating merchants or third party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and third party Service Providers to assess the results of their campaign; Create a record of the transaction data and thereafter maintain and use data in connection with operating the Spire Loyalty; Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant. Members authorize the sharing, exchange and use of transactional information described above and herein by and among Company and Company’s third party Service Providers, applicable Payment Card Networks and applicable Merchants.
Capitalized terms used but not otherwise defined in this “Collection and Use of Transactional Information” section shall have the meanings ascribed thereto in the Spire™ Loyalty Rewards Program Terms and Conditions.
By registering a payment card in connection with transaction monitoring, you authorize Spire Loyalty to share your payment card information with Visa, Mastercard and AMEX (Payment Networks) so it knows you enrolled. You authorize Mastercard, Visa and AMEX to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Visa, Mastercard and AMEX (Payment Networks) to share such transaction details with Spire Loyalty to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by navigating to your settings menu to remove your linked card(s).
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:
We have implemented measures designed to secure your personal information and transactional information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via 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.
The Company is a United States company governed by the state and federal laws of the United States. The Website are hosted on servers located in the United States or other countries. The laws of those countries, including their data privacy laws and laws regarding transfer of data across borders, may differ from the laws in your country. If you are not located in the United States, you use the Website at your own risk.
SPIRE TECHNOLOGY INC, a Delaware corporation (“Company,” “we,” “our,” or “us”) provides this supplemental privacy notice (“CCPA Notice”) for consumers that reside in California (“you,” or “your”) as required under California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Notice applies to the Company and its affiliated operating companies (“Affiliates”).
We provide this CCPA Notice to inform you about how we collect, use or disclose your personal information. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA. This CCPA Notice supplements our Privacy Notice. In the event of a conflict between our Privacy Notice and this CCPA Notice, this CCPA Notice will prevail for California residents and their rights under California law.
Personal information we collect, use, or disclose that is governed by the federal Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the federal Fair Credit Reporting Act, such as consumer credit reports or information relating to your financing of a StaySaver Vacations™ product or service, is not subject to the CCPA and this CCPA Notice.
The type of personal information we collect, use, and disclose will depend on your interaction or relationship with us. The chart below generally identifies the personal information we collect based on the categories of personal information set forth in the CCPA.
|Categories of personal information as set forth in the CCPA||Personal information we collect|
|Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||We may collect information such as your name, address, email address, telephone numbers, date of birth, member number, and IP address.|
|Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.||Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial or payment information. We may collect information such as your name, address, email address, telephone numbers, member number, and credit or debit card information.|
|Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.||We may collect information such as your gender or age. In more limited circumstances, we may collect disability information in an effort to provide you with appropriate facilities or services.|
|Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||We may collect information such as the products or services you purchased or utilized.|
|Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.||We may collect voice recordings when we monitor and record telephone calls.|
|Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.||We may collect this information as part of your interaction with our Website (as defined in our Privacy Notice) or mobile application, and through advertisements.|
|Geolocation Data: Precise geographic location information about a particular individual or device.||We may collect information such as your postal address, zip code, or the location associated with an IP address or particular device.|
|Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).||Audio, Video and other Electronic Data: We may collect voice recordings when we monitor and record telephone calls, photos or videos that are tagged or shared with us through social media posts, or audio, video, or images captured in security footage of our business locations.|
|Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record.||We do not collect this information.|
|Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).||We do not collect this information.|
|Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.||We may collect or derive information such as your preferences, characteristics, predispositions, and behavior based on other information we have about you.|
We collect these categories of personal information from the sources described in our Privacy Notice and for the purposes described in the “Information We Collect and Its Uses” section of our Privacy Notice. We disclose your personal information to third parties, such as our service providers, as described in the “Disclosure of Information” section of our Privacy Notice. We do not collect personal information directly from children under the age of eighteen (18), but may receive such information from parents and guardians when, for example, making resort, cruise, or other travel reservations.
We may also use standard internet technology, such as cookies, web beacons, pixels, and other similar technologies (collectively “cookies”) to track your use of our Website as defined in our Privacy Notice. We may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. See the “Cookies & Related Technologies” section of our Privacy Notice for more information. Data that is collected through network advertising or social media cookies may be disclosed by such network advertisers or social media to other network advertisers that allows those advertisers to also display ads to you. While there is currently no industry consensus, we do not consider these additional disclosures to be our sale of personal information under the CCPA. If you do not want information collected by cookies, however, please visit www.aboutads.info and www.networkadvertising.org to opt-out.
If you are a California resident, you have certain rights with respect to your personal information as set forth below.
Request to Delete: You may request that we delete personal information we have collected about you, subject to certain exemptions provided by law.
Request to Know: You may request, subject to certain exemptions, that we disclose to you the categories of personal information collected; the categories of sources of personal information; the business or commercial purposes for collecting and selling your personal information; the categories of third parties with whom we have shared your personal information; the categories of personal information that we have disclosed or shared with a third party for a business purpose; the categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; and the specific pieces of personal information that we have collected about you in the prior 12 months.
Request to Opt-out of Our Sale of Your Personal Information: We do not sell your personal information.
Submitting Requests: To make a Request to Delete or a Request to Know, please contact us at [email protected]. Please include your full name, postal address, email address, and your member number (if applicable). If you designate an authorized agent to make a request on your behalf, we require you to provide a written and signed authorization of your agent’s permission to exercise your rights on your behalf as provided for in this section. Please include your full name, postal address, email address, and your member number (if applicable) along with your agent’s full name, postal address, email address, and relationship to you.
If we are unable to verify your identity based on this information, we will take additional steps to verify your identity before responding to your request. We will respond to verifiable requests received from California residents or their authorized agents in accordance with the law, which provides certain exemptions for disclosure or deletion. For example, if you enroll in the Spire Loyalty Program, we may retain your personal information as permitted by law to maintain and service your membership and account.
These rights do not apply to personal information we collect about job applicants, independent contractors, or our current or former full-time, part-time and temporary employees and other staff, or information we collect when we act as a service provider.
Non-Discrimination: We are not permitted to nor do we discriminate against California residents who exercise their rights under the law.
We do not permit personal information as defined by California’s Shine the Light law that we share with third parties to be utilized for their marketing activities. If you are a customer who resides in the State of California, however, you have the right to request from us a list of third parties with whom we shared personal information about you for their own direct marketing purposes during the previous calendar year by contacting us at [email protected] or by sending a letter to Spire Loyalty, 1 Town Center Rd #600, Boca Raton, FL 33486 . Privacy rights under Shine the Light and the CCPA are provided under different legal rules and must be exercised separately.
At this time, we do not respond to browser “do not track” signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our Website.
This CCPA Notice was last updated on June 8, 2021.
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