TRUST ASSURANCE PRIVACY POLICY

Last Modified: February 26, 2020

This “Privacy Policy” describes the treatment of information provided or collected on the websites, mobile applications, web applications or “widgets”, and other applications and functionality related to the use and consumption of literary works and other content (the “Service” or “Services”) provided by SpoonRead Inc., also doing business as Trust Assurance. (“we”, “us”, “our”, “SpoonRead”, “Trust Assurance” or “Trust Assurance Network”). It also explains the treatment of information provided or collected on applications we make available on third-party sites or platforms if disclosed to you in connection with the use of the application.

Contents

1. Types of Information We Collect
2. How We Collect Your Information
3. Use of Your Information
4. Sharing Your Information with Third Parties
5. Your Controls and Choices
6. Data Security, Integrity, and Retention
7. Changes to this Privacy Policy
8. Comments and Questions
9. Definitions

1. Types of Information We Collect

We collect two basic types of information – personal information and anonymous information – and we use personal and anonymous information to create a third type of information, aggregate information. We collect the following categories of information:

  • Information you provide when you create an account, which may include your name, country of residence, gender, date of birth, email address, username, and password.
  • Information you provide when you request information or purchase a product or service from us, whether on our sites or through our applications, including your postal address, telephone number, and payment information
  • Other information you provide publicly, through the Service, and/or sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information
  • Information you provide to us when you use our sites and applications, our applications on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account
  • Location information when you visit our sites or use our applications, including location information either provided by a mobile device interacting with the Services, or associated with your IP address, where we are permitted by law to process this information. We may use IP addresses to collect information regarding the frequency with which you visit various parts of our sites and applications, and we may combine IP addresses with personal information.
  • Usage, viewing, and technical data, including your device identifier or IP address, when you visit or use the Service sites, use our applications on third-party sites or platforms or open emails we send

2. How We Collect Your Information

We collect information you provide to us when you request products, services or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to customer surveys, use the Service, or otherwise interact with us using one or more devices. When you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.

We collect information through technology, such as session information, cookies, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices. Please review your device and application settings to learn how to disable cookies or other tracking.

We may acquire information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.

3. Use of Your Information

We may use your information for the following purposes:

  • Provide you with the products and services you request
  • Communicate with you about your account or transactions with us and send you information about features on our sites and applications or changes to our policies
  • Consistent with applicable law and choices and controls that may be available to you we may use information collected from you, or from devices associated with you, to:
    • Send you offers and promotions for our products and services or third-party products and services
      Personalize content and experiences
    • Provide you with advertising based on your activity on our sites and applications and on third-party sites and applications.
    • Optimize, maintain, or improve our products, services, and operations
    • Detect, investigate and prevent activities that may violate our policies or be illegal or protect the security and integrity of the Services

4. Sharing Your Information with Third Parties

We will not share your personal information with third parties except in limited circumstances, including:

  • When you allow us to share your personal information with another company, such as:
    • Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services
    • Directing us to share your personal information with third-party sites or platforms, such as social networking sites
  • When we share personal information:
    • With third parties in connection with the sale of a business
    • To enforce our Terms of Service or rules
    • To ensure the safety and security of our users, customers, and other third parties
    • To protect our rights and property and the rights and property of third parties
    • To comply with legal process or in other cases if we believe in good faith that disclosure is required by law

Once we share your personal information with another entity other than a service provider, the information received by the other company becomes subject to the other company’s privacy practices.

5. Your Controls and Choices

In accordance with applicable law, we provide you the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Your controls and choices may include:

  • You may correct, update, and delete your account
  • You may change your choices for subscriptions, newsletters, and alerts
  • You may request access to the personal information we hold about you and that we amend or delete it

6. Data Security, Integrity, and Retention

The security, integrity, and confidentiality of your information are important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. Despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

7. Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.

8. Comments and Questions

If you have a comment or question about this privacy policy, please contact us in writing at
9515 Soquel Dr.Suite 211 Aptos, CA 95003. Our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

Notice to California Residents: If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request and obtain from us once a calendar year information about the customer information we shared, if any, with third parties for their own direct marketing use. If applicable, this information would include the categories of your information and the names and addresses of those third parties with which we shared such information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any requests, contact usinfo@spoonread.net or 9515 Soquel Dr.Suite 211 Aptos, CA 95003.

9. Definitions

Aggregate Information. “Aggregate information” means information about groups or categories of our users or customers, which does not identify and cannot reasonably be used to identify any single individual.

Anonymous Information. “Anonymous information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, any single individual.

Application. “Application” means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile or other platforms and environments, including those operated by third parties, which permits us to interact directly with our users.

Children. “Children” refers to individuals who are under 13 years of age.

Notice. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

Parents. The term “Parent” or “Parents” means one or more parents or legal guardians.

Personal information. “Personal information” means information that identifies or could be used to identify (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address and telephone number. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.