Privacy Policy

This Privacy Policy describes how Spiraf, LLC ("we", "us", "our") collects, uses, shares, and safeguards your information.

Overview

This Privacy Policy applies to our website, applications, products, and services that link to this policy or otherwise refer you to this policy (collectively, our "Services").

We used Privacy Policy Ace to generate this Privacy Policy.

Information Collection and Use

Personal Data

When you use our Services, we may collect Personal Data, which refers to any information that identifies you personally. This includes, but is not limited to:

• Contact information such as your name, email address, mailing address, and phone number.
• Billing information such as credit card number, and billing address ( Handled by Stripe )
• Demographic information such as age, education, gender, interests, and zip code.

Non-Personal Data

We may also collect non-personal data, which is data that cannot be directly linked to an individual. This includes browser and device information, application usage data, information collected through cookies, pixel tags, and other technologies, and demographic information.

Use of Information

We use the information we collect for purposes including:

• Providing, maintaining, and improving our Services.
• Processing transactions and sending related information.
• Sending promotional communications.
• Responding to user inquiries and providing customer support.
• Conducting research and analysis.
• Ensuring network and information security.

Information Sharing

We may share your personal information with third parties under the following circumstances:

• With your consent.
• With third-party vendors and other service providers that perform services on our behalf.
• If we believe disclosure is necessary to comply with relevant laws, to respond to legal requests, or to protect our rights, property, or safety.
• In connection with any merger, sale of company assets, or acquisition.

Cookies and Tracking Technologies

We may use cookies, pixel tags, analytics services (such as Google Analytics), logs, and various other tracking technologies to automatically collect information. You have the right to disable cookies at your browser level, though this may affect your ability to use certain features of our Services.

Security

We employ reasonable physical, technical, and administrative measures designed to safeguard the information we collect. However, no security measure is 100% secure, and we cannot guarantee the absolute security of your information.

International Data Transfers

Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. Your personal information may be subject to privacy laws that are different from those in your country.

Your Rights and Choices

Depending on your location, you may have certain rights in relation to your personal information. These may include: the right to access, rectification, erasure, restrict processing, or object to processing of your personal data, and the right to data portability.

Children's Privacy

Our Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

GDPR Notice

Legal Basis for Processing Personal Data

Under the General Data Protection Regulation (GDPR), we must have a legal basis to process your personal information. We process your information on the following legal bases:

• You have consented to the use of your personal information. For example, we may seek to obtain your consent for our uses of cookies.
• We need your personal information to provide you with services and products requested by you, or to respond to your inquiries.
• We have a legal obligation to use your personal information.
• We have a legitimate interest in using your personal information.

Transfers of Personal Data

The personal data that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to the United States, where we have our data centers.

of Personal Data

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Data Subject Rights

Under the GDPR, you have the following rights:

• Right to Access: You have the right to request access to your personal data that we hold.
• Right to Rectification: You have the right to correct any inaccurate personal data about you and to complete any incomplete personal data about you.
• Right to Erasure (the "Right to be Forgotten"): In certain circumstances, you have the right to the erasure of your personal data from our systems.
• Right to Restrict Processing: In certain circumstances, you have the right to restrict the processing of your personal data.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
• Right to Object: In certain circumstances, you have the right to object to the processing of your personal data.
• Right to Withdraw Consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time.

Exercising Your GDPR Data Protection Rights

You may exercise any of your rights in relation to your personal data by written notice to us addressed to the following: contact@xpage.ai

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO at contact@xpage.ai.

CCPA Notice

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: such as name, address, email address.
• Personal information: as defined in the California customer records law, such as contact information and financial information.
• Internet activity: such as your interactions with our Service.
• Geolocation data: such as device location.
• Professional or employment-related information: such as job history or employer information.
• We may use your personal information for the purposes listed in this Privacy Policy.

Our Personal Information Selling Practices

We do not sell your personal information in the traditional sense. We do share your information as outlined in the Information Sharing section of this Privacy Policy.

Rights Under CCPA

If you are a California resident, you have the following rights:

• Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
• Right to Delete: You have the right to request the deletion of your personal information that we have collected or maintain, subject to certain exceptions.
• Right to Opt-Out: You have the right to opt out of the sale of your personal information.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Exercising Your CCPA Data Protection Rights

To exercise any of your rights under the CCPA, please contact us using the following methods:

• Email: contact@xpage.ai
• Website: https://www.xpage.ai

Please note that we may need to verify your identity before processing your request, which may require additional personal information from you. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes will be posted on this page and your continued use of our Services after any changes have been posted will constitute your agreement to such changes.

This Privacy Policy was generated with Privacy Policy Ace.

Contact Us

If you have any questions about this Privacy Policy, please contact us at contact@xpage.ai.

Last updated: 12/24/2023