Privacy Policy

Remember that your use of Spiral’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on our website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What Does This Privacy Policy Cover?

This Privacy Policy covers how Spiral collects and processes data that identifies or relates to you (“Personal Data”) This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data We Collect

Device or Web Data. If you interact with us online (e.g., by visiting our website or using our web-based Services), we may collect information about your Device such as your IP address, IP address-based location data, device ID, and type of device or operating system used to connect with us.

Contact Data. We may collect your contact information such as your name, email, phone number, employer, and job title if you sign up for a demo, subscribe to our newsletters or other marketing communications, or otherwise sign up for our Services.

Other Personal Data. We may collect other Personal Data that you make available through Services or to us, such as in emails, letters, texts, or other communications you send us.

Our Sources of Personal Data

From You. We collect Personal Data when you provide it directly to us (e.g., you create an account or contact us) and certain Personal Data (such as Device or Web Data) automatically when you use our Services (e.g., through Cookies – as defined in the “Tracking Tools” section below), or if you download or install an application as part of our Services.

Third Parties. Such as:

• Vendors that provide analytics on how you interact an engage with our Services or that help provide you with customer support.

• We may also use Vendors to help generate leads. Advertising Partners who may assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Purpose for Collection and Processing Personal Data

To Provide, Customize, and Improve our Services

• Providing you with the products, services or information you request.

• Meeting or fulfilling the reason you provided the information to us.

• Providing support and assistance for the Services.

• Improving the Services, including testing, research, internal analytics and product development.

• Personalizing the Services, website content and communications based on your preferences.

• Doing fraud protection, security and debugging.

Marketing our Services

• Marketing and selling the Services.

• Showing you advertisements, including targeted advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Company or the Services.

• Sending emails and other communications according to your preferences.

Legal or Security

• Meeting legal requirements and enforcing legal terms.

• Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

• Protecting the rights, property or safety of you, Spiral or another party.

• Enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

Who We May Share Personal Data With

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They may include: hosting, technology and communication providers; security and fraud prevention consultants; support and customer service vendors; product fulfillment and delivery providers; analytics providers that analyze the use of our Services;

Business Partners. These parties partner with us in offering various services. They may include businesses that you have a relationship with, and companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate. This includes third parties you access or interact with through the services, social media services, and other users.

Others. We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Legal or Security” subsection above. All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Tracking Tools

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) that may collect or facilitate the collection of your Personal Data for various purposes. We may also supplement the information we collect via Cookies with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We may use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services.

• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information such as the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. These Cookies help us better understand user of our Services and can also help us measure our targeted advertising efforts.

• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.

Most internet browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

Data Security and Retention

Although we work to protect the security of your account and Personal Data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. You can help protect your Personal Data by practicing password hygiene – for example, by creating strong and unique passwords; securing your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for certain categories of Personal Data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at support@spiraldb.com.

State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@spiraldb.com.

Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• support@spiraldb.com

169 Madison Ave, STE 11081, New York, New York 10016