Spiralytics Online Privacy

Spiralytics Online
Privacy Statement

Data Privacy Act of 2012

Spiralytics Inc. (“Spiralytics”) complies with the Data Privacy Act of 2012 and is committed to safeguarding your privacy and ensuring that you continue to trust Spiralytics with your personal information. When you interact with us, you may share personal information with us which allows identification of you as an individual (e.g. name, email, address, telephone number). This is known as “personal information”.

This notice (“Privacy Notice”) sets out:

1. Scope and acceptance
2. Personal information collected by Spiralytics
3. Why Spiralytics collects personal information and how it uses it
4. Sharing of personal information by Spiralytics
5. Your rights
6. Cookies and other technologies
7. Information security and retention

Scope and acceptance of this Privacy Notice

This Privacy Notice applies to the personal information that we collect about you for the purposes of providing you with our products and services we offer.
By using Spiralytics Sites or by giving us your personal information, you accept the practices described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use Spiralytics Sites or give us any personal information.
Spiralytics reserves the right to make changes to this Privacy Notice at any time. We encourage you to regularly review this Privacy Notice to make sure you are aware of any changes and how your personal information may be used.

Information collected by Spiralytics

Spiralytics may collect personal information about you from a variety of sources, including through:

• Online and electronic interactions with us, including via Spiralytics website or through Spiralytics branded pages or applications on third-party social networks (e.g. Facebook, Twitter, etc.)
• Your interaction with online targeted content (such as advertisements) that Spiralytics to you via third party websites or applications.

Information that you provide to us directly
This is information that you provide to us with your consent for a specified purpose, including:
• Personal contact information, including any information allowing Spiralytics to contact you in person (e.g. name, home or (e)mail address, and phone number);
• Demographic information, including date of birth, age, gender, location (e.g. zip code, city and state and geo-location), favorite products, hobbies, interests, and household or lifestyle information;
• Payment information, including to make purchases (e.g. credit card number, expiration date, billing address);
• Account login information, including any information that is required for you to establish a user account with Spiralytics (e.g. login ID/email, user name, password and security question/answer); and
• Feedback, including information that you share with Spiralytics about your experience in using Spiralytics services (e.g. your comments and suggestions, testimonials and other feedback related to Spiralytics service)

Information that we collect when you interact with Spiralytics Sites
We use cookies and other tracking technology which collect certain kinds of information when you interact with Spiralytics.

Information collected from other sources
We may collect information about you from other legitimate sources for the purpose of providing you with our services. Such sources include third-party information aggregators, Spiralytics promotional partners, public sources and third party social networking sites with whom you have given consent for the disclosure of information relating to you and where otherwise lawfully permitted. Such information may include:
- • Personal contact information
- • Any personal information that is part of your profile on a third party social network (e.g. Facebook) and that you allow that third party social network to share with us (e.g. name, email address, gender, birthday, city, profile picture, user ID, friend list). You can learn more about the information that we may obtain about you by visiting the website of the relevant third party social network.
We may also receive personal information about individuals when we acquire other companies.

Why Spiralytics collects personal information and how it uses it

Spiralytics collects and uses personal information only as necessary for the purposes for which it was obtained. Spiralytics may use your personal information for some or all of the following purposes:

• Client service – to provide you with consumer service, including responses to your inquiries, complaints and general feedback about our services. Client service may be provided through various forms of communication, including via email, letter, telephone and online chat features.

• Client engagement – to get you more actively engaged with our services.

• Websites – to improve and personalize your experience on websites, using information such as account login information, technical computer information, and/or previous website usage information;

• Marketing communications – to provide you with marketing communications where you have opted-in to receive such communications (including information about Spiralytics, its services, and promotions). These can be shared via electronic means (e.g. SMS, emails and online advertising) and via post.

• Third-party social networking
Spiralytics may use your personal information from when you interact with third party social networking features such as “Facebook Connect” or “Facebook Like”. These features may be integrated on Spiralytics website.

If you use these features, Spiralytics may have the ability to obtain certain personal information about you from your social networking information. You can learn more about how these features work, and the profile information Spiralytics may obtain about you, by visiting the website of the relevant third party social network.

We may use your personal information for other specific business purposes, including to maintain the day-to-day operation and security of Spiralytics website, to conduct demographic studies or audits, and to contact you for consumer research.

• Other specific purposes

Sharing of Personal Information by Spiralytics

Spiralytics does not share your personal information with any third party that intends to use it for direct marketing purposes unless you have provided specific consent in relation to this.

Spiralytics may share your personal information with third parties for other purposes, but only in the following circumstances:

Affiliates
Spiralytics may share your personal information with its affiliates or related companies for internal business purposes, including for customer support, marketing, and technical operations.

Service Providers
Spiralytics may engage service providers, agents or contractors to provide services on its behalf. These third parties may come to access or otherwise process your personal information in the course of providing these services.
Spiralytics requires such third parties, to comply with all relevant information protection laws and security requirements in relation to your personal information, usually by way of a written agreement.

Partners and Joint Promotions
Spiralytics may run a joint or co-sponsored program or promotion with another company and, as part of your involvement in the activity, collect and use your personal information.

Your personal information will only be shared with another company if you have opted in to receive information directly from that company. Spiralytics encourages you to read the privacy notice of any such company before sharing personal information. If you do not want your personal information to be collected by or shared with a company other than Spiralytics, you can always choose not to participate in such activity.

If you do opt-in to communications from such a company, remember that you always have the right to opt-out and you would need to contact that company directly to do so.

Legal requirements and Business Transfer
Spiralytics may disclose your personal information if it is required to do so by law or if, in Spiralytics’s good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims.
In the event of a full or partial merger with, or acquisition of all or part of

Spiralytics by another company, the acquirer would have access to the information maintained by that Spiralytics business, which could include personal information.

Your Rights

You are afforded rights in relation to your personal information under the Data Privacy Act of 2012, including the right to access, correction, and objection to the processing, including the right to lodge a complaint with the National Privacy Commission.

You have a right to request access to your personal information. You may send a request for access via the Spiralytics website. Depending on the nature of the request, Spiralytics may charge a reasonable fee for providing access to your personal information.

Cookies and other tracking technologies

What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

How and why do we use cookies?
We use cookies to improve the use and functionality of Spiralytics website and to gain a better understanding of how visitors use Spiralytics website and the services offered to them. Cookies help us tailor Spiralytics website to your personal needs, to improve their user-friendliness, gain client satisfaction feedback and to communicate to you elsewhere on the internet.

What types of cookies may be used on Spiralytics website?
We may use the following types of cookies on Spiralytics website:
- Session cookies – These are temporary cookie files which are erased when you close your browser. When you restart your browser and go back to the site that created that cookie, the website will treat you as a new visitor.
- Persistent cookies – These cookies stay on your browser until you delete them manually or until your browser deletes them based on the duration period set within the cookie. These cookies will recognize you as a return visitor.
- Necessary cookies – Necessary cookies are strictly necessary for the operation of a Spiralytics website. They enable you to navigate around the site and use our features.
- Cookies that send information to us
  These are the cookies that we set on a Spiralytics website and they can only be read by that site. This is known as a “First Party” cookie.
- We also place cookies on Spiralytics advertisements which are placed on other website owned by third parties (e.g. Facebook). We obtain information via those cookies when you click on or interact with the advertisement. In this situation, Spiralytics is placing a “Third Party” cookie.
  
  Spiralytics may use the information obtained by these cookies to serve you with advertising that is relevant and of interest to you based on your past online behavior.
- Cookies that send information to other companies – These are cookies that are set on a Spiralytics website by our partner companies (e.g. Facebook or advertisers). They may use the information collected from these cookies to anonymously target advertising to you on other websites, based on your visit to the Spiralytics website. For example, if you use a social widget (e.g. the Facebook icon) on a Spiralytics website, it will record your “share” or “like”. Facebook (as the company setting the cookie) will collect the information.

Other Similar Technologies
Spiralytics website also makes use of other tracking technologies including IP addresses, log files and web beacons, which also help us tailor Spiralytics website to your personal needs.

• IP addresses
An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may record IP Addresses for the following purposes: (i) troubleshoot technical concerns, (ii) maintain website safety and security (iii) better understand how our websites are utilized, and (iv) to better tailor content to your needs depending on the country you are in.

• Log Files
We (or a third party on our behalf) may collect information in the form of logs files that record website activity and gather statistics about a user’s browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our website, and which pages they’ve viewed on our website and for how long), and, (iii) other similar navigational or click-stream information (e.g. site traffic reporting and unique visitor counts).

• Web Beacons
We may use web beacons (or clear GIFs) on the Spiralytics website. Web beacons (also known as “web bugs”) are small strings of code that provide a method of delivering a graphic image on a web page for the purpose of transferring information back to us. We use web beacon information for a variety of purposes, including information as to how a user responds to email campaigns (e.g. the time the email is opened, where the user links to from the email), site traffic reporting, unique visitor counts, advertising and email auditing and reporting, and personalization.

Manage your cookies/preferences
You should ensure that your computer setting reflects whether you are happy to accept cookies or not. You can set your browser to warn you before accepting cookies, or you can simply set it to refuse them.

You do not need to have cookies on to use or navigate through many parts of Spiralytics website although you may not have access to all the features on Spiralytics website if you do so. See the ‘help’ button on your browser (e.g. Google Chrome, Firefox) for how you can do this.

Remember that if you use different computers in different locations, you will need to ensure that each browser is adjusted to suit your cookie preferences.
As a web beacon forms part of a webpage, it is not possible to ‘opt-out’ but you can render them ineffective by opting out of the cookies they set.

Information Security and Retention

Information security
In order to keep your personal information secure, Spiralytics has implemented secure operating environments – Spiralytics stores your information in secure operating environments and only accessible to Spiralytics employees, agents, and contractors on a need-to-know basis. Spiralytics also follows generally accepted industry standards in this respect.
Please note that this does do not apply to personal information you choose to share in public areas such as on community websites.

Retention
Spiralytics will only retain your personal information for as long as it is necessary for the stated purpose, taking into account also our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements under applicable laws.

This means that we may retain your personal information for a period of 10 years after your last interaction with us. When the personal information that we collect is no longer required, we destroy or delete it in a secure manner.