We at Sparemin, Inc. (“Sparemin,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that as an end user of our products and services, you (“you,”“your” or “end user”) care about how your information is used and shared.  This Privacy Policy relates to the information collection and use practices of Sparemin in connection with our video software-as-a-service currently called “Headliner” (“Software”).  The Software is made available through the websites located at headliner.app and editeddy.com (including any subdomains and successor websites) (“Site”) and/or via a mobile application(s) (“Mobile Apps”).  The Software, Site and Mobile Apps are collectively referred to herein as the “Service”.  

The Information We Collect and/or Receive

In the course of operating the Service, Sparemin will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1.            Personal Information

While you can browse through certain publicly-available information in the Service without registering for an account, in order to use all of the features and functionality of the Software, you will be required to create an account with us (“Account”).  You will be asked to provide certain registration details or other information, to enable you to create an end user Account and to help us provide the Service to you, including personal information about yourself, such as your name, e-mail address and certain information that will assist us in authenticating your identity when you log-into the Service in the future.  You may also be required provide identifiable information in order to access certain features of the Service (e.g., support).  If you choose to pay for the service, you may need to pay for the service through Stripe, where we will gain access to your Stripe ID, but will not receive any/all credit card information.

Please be advised that if you contact us, you will need to provide your name and e-mail address to enable us to respond to any requests or questions.  All information that personally identifies you is collectively called “Personal Information” in this Privacy Policy. We do not collect any Personal Information from you of the Service unless you provide to us voluntarily.

2.            Software Use Information

In connection with your use of the Software, the Service will collect data on what video, audio, images, and text are used within the video.  Sparemin may also store, process, and collect information on how the Software is used including mouse movement, clicks, and keyboard entry.

3.            Geolocation Information

Certain features and functionalities of the Service may only be used based on your location.  In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device or wireless carrier and/or certain third-party service providers.  Such information is collectively called the “Geolocation Information.”  Collection of such Geolocation Information occurs both when the Service is running on your mobile device and your desktop device.  You may decline to allow us to collect such Geolocation Information, in which case Sparemin will not be able to provide certain features or functionalities to you.

4.         Other Information.

In addition to the Personal Information, we may collect or receive additional information (collectively, the “Other Information”).  Such Other Information may include:

a.       From Your Activity.  In an ongoing effort to improve the Service, we may automatically collect certain information when end users access and use the Service.  Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Service end users visit, log files, and similar information and data.

b.      From Cookies.  We collect information using “cookie” technology.  Cookies are small packets of data that a Service stores on your computer’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect statistics in the aggregate about end user behavior, to help you access the Service and to enhance your experience using it.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer.  Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  However, if you decide not to accept cookies from us, the Service may not function properly.

c.       From You.  You may voluntarily provide us additional information about yourself that does not identify you personally, such as your gender, country, product and service preferences, and other information (including any content you access or upload to the Service).

d.      From Third-Party Services.  By submitting your certain information that will assist us in authenticating your identity when you log-into the Service, you authorize us to use that information to communicate with and receive information from the third-party platform to which such information relates (including, without limitation, a list of your followers or connections, your profile information, or information regarding your activity on such third-party platform). Third-party social media buttons displayed within the Service may record your IP address, browser type and language, access time and referring website addresses.  When you are logged in to those social media websites, they also may link this collected information with your profile information on that website. We do not control these third party tracking technologies.

If you connect to the Service using credentials from a third-party social media application such as Facebook, Instagram or Twitter (e.g., “Login with Facebook,” or “Sign In with Twitter”) (each, a “Social Media Site”), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information made available on or through your Social Media Site account, including your name, profile picture, country, hometown, email address, date of birth, gender, and networks. The Service will not store end user names or passwords from any Social Media Site or use any “friend” or “follower” data from any Social Media Site.

Do Not Track

We do not track our customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

How We Use and Share the Information  

You authorize us to use the Personal Information and the Other Information (collectively, the “Information”) to provide and improve our Service, products, and services; to process transactions you request; to contact you to discuss the support, renewal of our products and services (including by our service providers on our behalf).  Unless authorized and accepted by you, we will not inform you about our products and services and those of our promotional partners and we will not bring you customized content (such as newsletters) based on your activity on the Service.  We will contact you via email for service related notices though.

You also authorize us to use and/or share Information as described below.

·         We will access, use, and share the Information as required to fulfill our contractual obligations to you and to address your questions or requests regarding our products, services, and/or support.

·         We may employ other companies and individuals, such as service providers, to perform functions on our behalf.  Examples may include providing technical assistance, recruiting services, order fulfillment, customer service, and marketing assistance.  These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

·         In an ongoing effort to better understand our end users, and our Service, products and services and those of our promotional partners, we may analyze certain Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Service and/or such products and services.  This aggregate information does not identify you personally.  We may also disclose aggregated end-user statistics in order to describe the Service and these products and services to current and prospective business partners and to other third parties for other lawful purposes. 

·         We use a number of third party services to understand usage and improve the service.  These services (e.g., Google Analytics, Mixpanel, Sentry, and others) may have access to your email address, IP address, browser/machine details as well as other information.  We don’t share information with these services for any other purpose than better servicing our users (i.e., they are not shared for marketing purposes).  Information is not typically shared directly from us to them, but rather via their code running as part/along with our Service.  If a third party service contacts you for marketing purposes as a result of using SpareMin, please contact us via info@sparemin.com.  SpareMin aims to respect your privacy and will aim to only work with third party services that also adhere to similar standards.

·         The Service uses 3rd party billing services, e.g., Stripe, where we get access to your ID on that system (e.g., Stripe ID), but we do not ask for, receive, or ever store your credit card number and payment information

·         The Service may use “social plug-ins” which are provided and operated by Social Media Sites (such as Facebook, Instagram and Twitter) to enable you to share certain information from the Service on the applicable Social Media Sites. If you are logged into your account with a Social Media Site, it may be able to link information about your visit to our Service to your account or profile with the Social Media Site. Similarly, your interactions with the social plug-in may be recorded by the Social Media Site. We will display the information to be shared with the Social Media Site to you prior to submitting it to the Social Media Site for sharing. You understand and agree that that such information may be attributed to your account on the Social Media Site and may be published thereon

·         You understand and agree that any Social Media Site’s or any other third-party application’s use of information collected from you (or as authorized by you) is governed by the Social Media Site’s or third-party application’s privacy policies and your settings on the relevant service, and our use of such information is governed by this Privacy Policy and your Service account settings. 

·         We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

·         As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

·         To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Sparemin or others, or to prevent any other harm to yourself or others. 

How We Protect the Information

We take reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Service may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Service and its servers are operated in the United States and elsewhere.  Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to use the Service, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Services

The Service may contain links to third-party Services (e.g., YouTube API Services, Google [Google Privacy Policy and Google Security Settings], Facebook, Twitter, Instagram, and LinkedIn).  Sparemin has no control over the privacy practices or the content of these Services.  As such, we are not responsible for the content or the privacy policies of those third-party Services.  You should check the applicable third-party privacy policy and terms of use when visiting any other Services via the links provided and on their respective web properties.  By using any of these services you are agreeing to be bound by their respective privacy policies.

You may also consent to work with third parties from within the Service so that you can import recordings (e.g., Zoom, Google Drive, SquadCast) or export videos (e.g., with YouTube). For example, you may share content from our Service to a social media platform or you may connect a file sharing application in order to import and edit your recording through our Service.

 Connecting to Google Drive and/or YouTube will grant the Service access to the following: name, email, ability to see and download Google Drive files, the titles and descriptions of your Google Drive files, and upload videos to your YouTube account. If you do not wish for the Service to have access to this information, do not connect with the third party integrations

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Service.  If you are under 13, please do not give us any Personal Information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Service without their permission.  If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

Accessing and Modifying Information and Communication Preferences

End users may access, remove, review, and/or make changes to their Personal Information through the Service or by contacting us via email at info@Sparemin.com.  In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Sparemin marketing e-mail.  We will use commercially reasonable efforts to process such requests in a timely manner.

Retention

Your information will be stored on our servers for a maximum of 26 months.  If you would like deletion of your data for any reason, contact us via email at info@Sparemin.com.  We will use commercially reasonable efforts to process such requests in a timely manner.

California Residents

Effective as of January 1, 2020

If you are a California resident, the processing of some information may be subject to the California Consumer Privacy Acct (“CCPA”) and other applicable California state privacy laws.  This Notice does not apply to employment related personal information collected from California based employees, job applicants, contractors, or similar individuals.

We have collected the following categories of personal information within the last twelve (12) months:

Collected:

·         Identifiers. A real name, postal address, Internet Protocol address, email address, account name. To be clear, we do NOT collect identifiers such as a Social Security number, driver's license number, passport number, or other similar identifiers

·         Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, education, employment, employment history. To be clear, we do NOT collect personal information such as a Social Security number, passport number, driver's license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.  For bank information, we rely on a 3rd party payment processor (Stripe), and we do not hold any banking information

·         Commercial information. Records of SpareMin/Headliner purchase history

·         Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with our websites, applications, and/or advertisements

·         Geolocation data. Physical location, as related to IP address

·         Professional or employment-related information. Generic information on the type of organization you work at (e.g., Small Business, Large Business, Student, et cetera)

NOT Collected

·         Protected classification characteristics under California or federal law

·         Biometric information

·         Sensory data

·         Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

·         Inferences drawn from other personal information

Sales of Personal Information

Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity ever (including that we do not “sell” the personal information of minors under 16 years of age).  Under California Civil Code Section 1798.83, California residents who have an established business relationship with Sparemin may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes.  SpareMin does not share your information with 3rd parties for direct marketing purposes so there is no need to contact us to opt-out of this.  Sparemin does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose the same to you.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an e-mail to info@Sparemin.com with “PRIVACY POLICY” in the subject line or writing us at:

Sparemin Inc. – Attn: Privacy Policy

261 Madison Ave, 9th Floor

New York, NY 10016

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time.  Any such changes will be posted on the Service.  By accessing the Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.  Please refer back to this Privacy Policy on a regular basis.

How to Update or Correct Personal Information

If you would like to update, delete or correct any Personal Information in our records, please contact us via email.

How to Contact Us 

If you have questions about this Privacy Policy, please contact Sparemin via e-mail at info@Sparemin.com with “PRIVACY POLICY” in the subject line.