Privacy Policy

Effective as of March 25, 2025

This Privacy Policy describes how Spuree Labs, Inc. ("Spuree", the "site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from https://spuree.com/ (the "Site") or otherwise communicate with us (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you.

Information We Collect Directly from You

The information you provide directly to us through the Services may include:

• Identifiers and Contact Data: First and last name, email address, billing and mailing addresses, professional title, company name, and phone number.
• Demographic Data: City, state, country of residence, postal code, and age.
• Account Login and Profile Data: Username and password for online accounts, profile picture, preferences, and other information added to your account.
• Communications Data: Data from our interactions with you, including when you contact us via the Service, social media, or other means.
• Commercial and Transactional Data: Information related to orders or transactions you make through the Service.
• Inference and Marketing Data: Preferences for marketing communications and details about your engagement with them.
• Other Data: Surveys, feedback, and any other information you provide while using the Service.

Certain features of the Services may require you to directly provide information about yourself. You may choose not to provide this information, but doing so may limit your access to certain features.

Automatic Data Collection

We, along with our service providers and business partners, may automatically log information about your device, your interactions with the Service, and other online activities, including:

• Device Data: Information such as your device's operating system, browser type, screen resolution, IP address, unique device identifiers, language settings, mobile carrier, and general location information.
• Internet Network Activity Data: Data about your interaction with the Service, including pages you visit, time spent on pages, navigation paths, and your activity on different screens.
• Communication Interaction Data: Your interactions with emails, texts, or other communications, including whether you open or click links in our messages.

Information We Collect through Cookies

We also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

We may collect information about you or others through affiliates or non-affiliated third parties. For example, if you invite someone to use the Service, we may collect their contact details to fulfill your invitation. Please do not share someone else's information with us unless you have their permission to do so.

We may also combine information we collect from you through the Service with information from other sources. However, we do not control third parties' privacy practices, so we encourage you to review their privacy policies. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices.

How We Use Your Personal Information

We may use information about you for the following purposes, which include fulfilling our contract with you and for our legitimate business purposes:

Service delivery and operations

We may use your personal information to:

• provide, operate and improve the Service and our business;
• personalize our products and the services, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• facilitate your invitations to contacts who you want to invite to join the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service improvement, research, and analytics

We may use information about you to analyze your usage of the Service, improve the Service, conduct research, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

As part of our efforts to improve the Service, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by taking steps to remove information that makes the data personally identifiable to you. We may use aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.

Marketing and advertising

We, our service providers, and our third-party advertising partners may collect, receive and use your personal information for marketing and advertising purposes.

Direct marketing

We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the "Opting Out of Marketing Communications" section below.

Interest-based advertising

Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based, or targeted, advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Events, promotions and contests

We may use information about you to administer promotions and contests, communicate with you about promotions or contests in which you participate, and contact or market to you after collecting information about you at an event.

Compliance and protection

We may use information about you to: comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Your Rights and Choices

Depending on your location, you may have some or all of the rights outlined below regarding your personal information. These rights are not absolute, may apply only under specific circumstances, and in certain cases, we may decline your request as permitted by law. If you have an account with us through the Service, you can review and update certain account details by logging into your account.

• Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
• Right to Delete: You may have a right to request that we delete personal information we maintain about you.
• Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Opting Out of Marketing Communications: You can opt out of marketing emails by following the opt-out or unsubscribe instructions at the bottom of those emails or by contacting us directly. Please note that even if you opt out of marketing emails, you may still receive service-related or non-marketing communications.

Additional US state-specific and other jurisdiction-specific rights

In addition to the rights outlined above, your local laws may grant you additional rights, including:

• The right to know the categories and specific pieces of personal information we have collected, used, or shared;
• The right to delete, correct, or update your personal information;
• The right to prevent the processing of your information for direct marketing purposes (including processing based on profiling for direct marketing);
• The right to restrict how we process and disclose certain information about you;
• The right to object to specific processing activities involving your personal information;
• The right to revoke your consent for processing your personal information;
• The right to be free from discrimination for exercising your rights;
• The right to data portability.

You can exercise these rights by submitting a request via email to info@spuree.com. To ensure your privacy and security, we take reasonable measures to verify your identity and the authenticity of requests before fulfilling them. If we cannot verify your identity, we may be unable to process your request.

Residents of the European Economic Area and United Kingdom

Spuree acts as the "data controller" for the "personal data" (as defined under the General Data Protection Regulation) that we handle under this Privacy Policy. This means Spuree is responsible for determining how personal data is collected, used, and disclosed, in compliance with applicable laws.

Third Party Websites and Links

The Service may include links to websites, mobile applications, and other online services operated by third parties. Additionally, our content may appear within web pages or online services not affiliated with us. These links and integrations do not constitute an endorsement or imply any affiliation with the third parties. We do not control these third-party websites, mobile applications, or online services and are not responsible for their actions.

Security

We implement a range of technical, organizational, and physical measures to safeguard the personal information we collect. However, it's important to note that all internet and information technologies carry inherent security risks, and we cannot guarantee the absolute security of your personal information.

Data Retention

We will retain your information for only as long as necessary to provide the Service and for the other legitimate business purposes set out in this Policy such as safety, security, compliance, and dispute resolution.

International Users

Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you.